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2017 (3) TMI 136 - AT - Income TaxValidity of Assessing Officer’s assumption of jurisdiction u/s 153A - non recording of satisfaction notes - Held that:- We drew support from the clarifications issued by CBDT in its circular No. 25/2015 dated 31.12.2015 which is binding on Revenue to withdraw and not press such cases, as in the case on hand, where the AOs concerned, i.e. transferor and transferee have not recorded satisfaction note for proper assumption of jurisdiction for issue of notice under section 153C. In this view of the factual and legal matrix of this case, we hold that since the AOs concerned (i.e. transferor/transferee AOs) have not recorded any satisfaction notes for proper assumption of jurisdiction for issue of notices under section 153 the said notices issued under section 153C of the Act are held to be invalid - Decided in favour of assessee.
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