Section 153C notice invalid if separate satisfaction not recorded

Vivil Investments Pvt. Ltd. Vs DCIT (ITAT Mumbai)

Notice issued u/s 153C was invalid in case of non-recording of separate satisfaction note even if AO of searched and other person was same

Conclusion: Notice under section 153C was to be issued with recording of separate satisfaction note even if AO of searched person and the other person, i.e., assessee was one and the same,therefore, in absence of the same, any order passed, in pursuance of such notice was void ab-initio and liable to be quashed.

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