Section 153C Proceedings Invalid as AO Failed to Record Separate Year-Wise Satisfaction: ITAT Delhi

Sh. Sudesh Gahlot Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, allowed the assessee’s appeal and quashed the assessment framed under Section 153C of the Income-tax Act, 1961 for Assessment Year (AY) 2016-17, holding that the assumption of jurisdiction was invalid because it was based on a consolidated satisfaction note recorded for multiple assessment years. The assessee had filed his return of income declaring a total income of ₹45,30,940. A search and seizure operation under Section 132 was conducted on 10 October 2018 in the cases of M/s CIFSL, M/s BIDPL, and th...