Section 153C Fails for Want of Proper Satisfaction: Entire Search Assessment Quashed

Nirvaja Enterprises Private Limited Vs ACIT (ITAT Delhi) Search action in Himanshu Verma group led AO to treat Assessee company as one of 200 alleged shell entities & initiate proceedings u/s 153C for AYs 2012-13 to 2018-19 on the basis of a single consolidated satisfaction note. AO made additions treating bank credits as accommodation entries & estimated commission income @4% plus further addition @1%, which were upheld by CIT(A). ITAT quashed entire proceedings holding that mandatory jurisdictional conditions of section 153C were not satisfied. Tribunal noted that satisfaction note n...