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2012 (9) TMI 979 - AT - Income TaxAssessment u/s 153A - Registration u/s.12A denied - proof of charitable activities - Held that:- As examined the said satisfaction note very closely and found that the impugned reasons mentioned by the AO are silent in so far as any AY Specific- Incriminating-Information (ASII) or others ie unaccounted or undisclosed or hidden information to the revenue by the assessee. In our opinion, the impugned satisfaction note is very general one for six years. It is surprising to note that the AO has narrated some information against the Mr Navale HUF, which is not relevant for the present assessee. In the process, the AO totally missed the requirements of the law ie only the AY with the pending assessments and the AY with the AY specific incriminating documents/ transactions or seized asset should only be reopened under the provisions of the first proviso to section 153A of the Act and not otherwise. Decided in favour of the assessee
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