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2016 (8) TMI 1230 - AT - Income TaxAssessment u/s 153C - non-presence of satisfaction note - Held that:- In the present case, no satisfaction recorded under section 153C of the Act in the case of the person searched i.e. Shri P.L.Midha, there is total non-compliance of provisions of Section 153C of the Act. Therefore, the Assessing Officer in the case of the assessee has not validly assumed the jurisdiction under section 153C of the Act. Therefore, considering totality of facts and circumstances and position of law, as explained in the case of Shri Pawan Mangla (2016 (6) TMI 1220 - ITAT CHANDIGARH) we hold that the jurisdiction assumed under section 153C of the Act was lacking in the instant cases and therefore, the notices issued under section 153C of the Act are held not in accordance with law and assessments made under section 153C are quashed. The orders of authorities below are, accordingly, set aside and quashed. Resultantly, all additions made in assessment orders under section 153C r.w.s. 143(3) are deleted. - Decided in favour of assessee.
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