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2019 (10) TMI 724 - AT - Income TaxAssessment u/s 153C - whether no satisfaction have been recorded in the case of the person searched and that no incriminating material have been found to connect the assessee? - HELD THAT:- Since addition on merit have already been deleted and confirmed by us, therefore, this issue is left with academic discussion only. However, briefly, we may point-out that in this case satisfaction note have been recorded in the case of assessee instead of recording it in the case of person searched by A.O. of the assessee which is invalid. Further balance-sheet of the assessee have been referred to which was found during the course of search in the case of Triveni Group. Therefore, no satisfaction have been recorded in the case of the person searched and that no incriminating material have been found to connect the assessee with the impugned addition. It is balance-sheet of the assessee only which is already on the record of the Department as well in public domain. As relying on SINHGAD TECHNICAL EDUCATION SOCIETY [2017 (8) TMI 1298 - SUPREME COURT] there was no justification to assume jurisdiction under section 153C of the I.T. Act, 1961. In view of the above, we set aside the Orders of the authorities below and quash the assumption of jurisdiction under section 153C - Decided in favour of assessee
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