Valid satisfaction note mandatory for initiation of search assessment on ‘other person’: ITAT Mumbai

Dilip B Patel Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that for initiation of search assessment on the ‘other person’ recording of valid satisfaction note as required under section 153C of the Income Tax Act is mandatory. In absence of the same, subsequent framing of assessment order u/s 153C/143(3) of the Act is null in the eyes of law.

Facts-

Vide the present appeal, the appellant contested that there was search u/s 132 of the Act in

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