Section 153C Notice Invalid Due to Missing ₹50 Lakh Asset Satisfaction

DCIT Vs Subramaniam Kathiresan (ITAT Chennai) 153C Beyond Six Years Needs ₹50 Lakh Asset Satisfaction — Missing Jurisdictional Fact Quashes Entire Assessment Chennai ITAT dismissed Revenue’s appeal and upheld CIT(A)’s order quashing the assessment of Subramaniam Kathiresan for AY 2014-15, holding that the assumption of jurisdiction u/s 153C itself was bad in law. Search was conducted on a third party on 05-02-2020 and the satisfaction note u/s 153C was recorded only on 18-11-2022, making AY 2014-15 the 9th year for the purpose of section 153A/153C. The Tribunal held that once the case ...