Section 153C Order invalid if AO failed to Record Satisfaction Note

Shri Jagjit Singh Vs ACIT (ITAT Delhi) The issue under consideration is whether the assessment order passed by the assessing officer under section 153C is bad in law and void ab-initio? ITAT states that, when the assessment or reassessment, as the case may be, has been made u/s 153C, the necessary requirements to proceed with such initiation of assessment proceedings must be fulfilled. But, in the instant case, as discussed, the AO has failed to record the satisfaction note as required u/s 153C rather mechanically recorded the satisfaction and made the assessment. The contention raised by the ...