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2017 (3) TMI 1839 - AT - Income TaxAssessment u/s 153C - whether any satisfaction was recorded u/s 153A of the Act in the case of the person searched in order to initiate proceedings u/s 153C of the Act in the case of the assessee? - HELD THAT:- Even though the AO of the person searched and the assessee before us is the same, the requirement of law is that the satisfaction has to be recorded before initiating proceedings u/s 153C of the Act. Therefore, the Additional Grounds of appeal being legal grounds and the facts are already on record, we deem it proper to admit the grounds. Since the AO has reported that the satisfaction has not been recorded as required under the law, we are inclined to allow the additional ground and hold that the assessment u/s 153C is not sustainable. - Decided in favour of assessee.
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