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Section 153C notice invalid if separate satisfaction not recorded
Case Law Details
- Case Name
- Vivil Investments Pvt. Ltd. Vs DCIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2010-11
- Courts
- All ITAT, ITAT Mumbai
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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.
Held: Assessee had questioned validity of assessment order passed u/s 143(3) r.w...
