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Income Tax - Highlights / Catch Notes

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Validity of Initiation of proceedings u/s 153C - as argued ...

Income Tax

February 10, 2024

Validity of Initiation of proceedings u/s 153C - as argued satisfaction note of the searched person and satisfaction note of the petitioner (other than the searched person) are verbatim, proceedings are invalid - The High Court observed that, having noted the fact that the satisfaction note of the AO of the petitioner assessee has not been brought on record and moreover, the assessment note of the AO of the searched person indicates a prima facie case of inquiry against the petitioner, we do not find any substance in the argument of the learned Senior Counsel that the satisfaction note of the AO of the petitioner is to be discarded being a copy in verbatim of the satisfaction note of the AO of the searched person.

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