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2023 (10) TMI 980 - KERALA HIGH COURTValidity of assessment u/s 153C - As argued Notice issued u/s 153C has not mentioned/specified the satisfaction note recorded by the 2nd respondent of the searched person and satisfaction notes do not bear the DIN number - HELD THAT:- The satisfaction notes recorded by the Assessing Authority, which have been placed on record would suggest that the Assessing Authority has examined the documents and recorded satisfaction for issuing notices u/s 153C. The petitioner has demanded the satisfaction note, and the letter issued by the ACIT whereby the satisfaction notes have been provided to the petitioner on his demand, would disclose that the letter bears the DIN number. The satisfaction note need not bear the DIN number, and this Court does not find any substance in the submission of the learned Counsel for the petitioner that since the satisfaction notes do not bear the DIN number, whole proceedings are invalid. The satisfaction note is a document prepared by the Assessing Authority which is kept in the file, and unless an assessee demands the satisfaction note, it is not required to be provided to the assessee. Therefore, there is no requirement to have a DIN number in the satisfaction note recorded by the Assessing Authority. Thus it cannot be said that the impugned notices and assessment orders are without jurisdiction as submitted by the learned Counsel for the petitioner.
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