This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Section 153C Notice Invalid Due to Missing ₹50 Lakh Asset Satisfaction
Case Law Details
- Case Name
- DCIT Vs Subramaniam Kathiresan (ITAT Chennai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2014-15
- Courts
- All ITAT, ITAT Chennai
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
Advertisement
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 th...
Author Info
