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2022 (8) TMI 1129 - AT - Income TaxAssessment u/s 153C - satisfaction recorded before the issue of notice or not? - HELD THAT:- In the instant case, inspite of repeated requests from the AR, the Revenue has not produced any satisfaction note either to the assessee or before us. Further, it is also noted from the letter of the DCIT, Circle-3(1), Visakhapatnam that the satisfaction recorded before the issue of notice U/s. 153C was not found as per the order sheet notings. From the Circular No. 24/2015, dated 31/12/2015 it is noticed in para 4 that even if the AO of the searched person and the other person is one and the same, then also AO is required to record the satisfaction, as held by the various Courts. In the instant case, no such material has been brought before us by the ld. DR - Since the satisfaction was not recorded by the Assessing Officer before issue of notice U/s. 153C we are of the considered view that the order passed by the Ld. CIT(A) U/s. 153C of the Act deserves to be set aside for all the impugned assessment years - Assessee appeal allowed.
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