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2023 (6) TMI 765 - AT - Income TaxValidity of the assessment framed u/s 153C - mandation of satisfaction note recorded by the AO - searched person having recorded satisfaction of documents found during search belonging to the assessee - HELD THAT:- The arguments now being raised before us have already been dealt with by the ITAT in the first round and no grievance against the findings of the ITAT on the issue was raised by the assessee its MA, this issue stand adjudicated by the ITAT for all purposes, and the assessee is not entitled to, therefore, rake up this issue again during the hearing in recall, which as we have noted above is limited in scope, to adjudicate only the mistake in the order of the ITAT in the first round. We hold that the argument of the assessee that for a valid assumption of jurisdiction under section 153C of the Act, the AO of the searched person has to mandatorily record satisfaction of material or documents found during the course of search belonging to the assessee, is misplaced and against principles of law admittedly laid down in the case of Super Mall P. Ltd. (2020 (3) TMI 361 - SUPREME COURT] and is rejected
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