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2018 (4) TMI 176 - AT - Income TaxValidity of assessment u/s 153C - as per assessee ‘satisfaction’ has not been recorded in the case of the person who was searched u/s.132(1), that is, in whose case assessment was to be framed u/s.153A - Held that:- There is no dispute with regard to the fact that the ‘satisfaction’ in terms of Section 153C has not been recorded in the case of the person searched in whose case assessment has been framed u/s.153A, albeit the ‘satisfaction’ has been recorded by the Assessing Officer in the case of the assessee. This is also apparent from the clear cut finding of the ld. CIT (A) that the ‘satisfaction note’ has been recorded in the assessee’s file and not in the file of the person searched. See SSP Aviation Ltd. vs. DCIT [2012 (4) TMI 335 - DELHI HIGH COURT] and CIT vs. Meghna Organics (2011 (4) TMI 1329 - GUJARAT HIGH COURT) - Decided against revenue
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