2021 (12) TMI 550 - ITAT DELHI - Income Tax

Head Note / Extract:
Assessment u/s 153C - Mandation of recording satisfaction - Whether satisfaction note recorded by the AO has not brought out any seized material belonging to the assessee-company, in fact, there is no incriminating document? - HELD THAT:- It is an admitted fact that, firstly, the satisfaction note recorded by the AO does not mention or is based on any seized material belonging to the assessee company and consequently, the additions made by the AO has no co-relation with any seized material. The aforesaid finding of the CIT(A) has not been rebutted by any material placed on record. Therefore, the aforesaid findings of CIT(A) is based on legal principles upheld by the Hon’ble Jurisdictional High Court as well as Supreme Court in the case of PCIT vs. Sinhgad Technical Education Society [2017 (8) TMI 1298 - SUPREME COURT] - Thus the ground of Revenue is dismissed.