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2019 (2) TMI 164 - AT - Income TaxAssessment u/s 153C - recording of satisfaction note - Held that:- It is not in dispute that search was conducted in the cases of Shri B.K. Dhingra and Others on 20.10.2008 and during the course of search certain documents belonging to assessee were seized. Accordingly proceedings under section 153C were initiated by recording the satisfaction note Dated 08.09.2010 for assessment year under appeals i.e., 2003- 2004 to 2008-2009 (PB-1). It is also not in dispute that the search in the cases of Shri B.K. Dhingra and Others connected to cases were of M/s. RRJ Securities Ltd., and M/s. Sanchit Consultants Pvt. Ltd.. The ITAT, Delhi G-Bench, in the case of M/s. Sanchit Consultants Pvt. Ltd.[2018 (2) TMI 434 - ITAT DELHI], following the decision of RRJ Securities Ltd. [2015 (11) TMI 19 - DELHI HIGH COURT], on identical facts concluded that the assessments made by the A.O. under section 153C of the I.T. Act for A.Ys. 2003- 2004 and 2004-2005 are beyond the scope of Section 153C and the same being void abinitio, deserves to be quashed. - Decided in favour of assessee.
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