No Year-Specific Satisfaction, No Valid U/s 153C Proceedings

Bharat Kumar Bansal Vs ACIT (ITAT Hyderabad) One Satisfaction Can’t Fit Seven Years: ITAT Hyderabad Quashes Section 153C Proceedings for Consolidated Satisfaction Note The ITAT Hyderabad allowed the assessee’s appeals for AYs 2013–14 to 2019–20, holding that the initiation of proceedings under section 153C was invalid in law as it was based on a single consolidated satisfaction note covering multiple assessment years. A search under section 132 was conducted on a third party on 22.11.2018, during which an agreement of sale dated 28.08.2018 was seized. Relying on this document, the Asse...