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2023 (6) TMI 354 - HC - Income TaxAssessment u/s 153A - necessity of recording satisfaction by AO of the searched person - HELD THAT:-No satisfaction was recorded by the AO of the searched persons and therefore, the order of the Tribunal in Smt. G. Lakshmi Aruna [2016 (10) TMI 1378 - ITAT BANGALORE] and the judgments of M/s. Gopi Apartment [2014 (5) TMI 158 - ALLAHABAD HIGH COURT] and in the case of Calcutta Knitwears [2014 (4) TMI 33 - SUPREME COURT] and Manish Maheshwari [2007 (2) TMI 148 - SUPREME COURT] are applicable to the given facts and circumstances of the case. These judgments were followed by the Income Tax Appellate Tribunal to hold that the notice issued by the AO u/s 153-C of the IT Act deserves to be quashed and accordingly had proceeded to quash the assessment orders framed by the AO u/s 153-C read with Section 143(3) of the Income Tax Act. Accordingly, the additional ground was allowed in all the seven years.
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