Section 153C Invalid Without Separate Satisfaction for Each Year: ITAT Delhi

Parveen Garg Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, adjudicated an appeal filed by the assessee against the order of the Commissioner of Income Tax (Appeals) for Assessment Year 2020–21. The Tribunal first condoned a delay of 24 days in filing the appeal, accepting the assessee’s explanation that the delay was due to lack of awareness of the appellate proceedings and the impugned order. The dispute arose from assessment proceedings initiated under Section 153C read with Section 143(3) of the Income Tax Act, following a search conducted in another person’s c...