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2016 (6) TMI 1472 - AT - Income TaxAssessment u/s 153A - mandation of recording satisfaction - unaccounted cash receipts - Whether the seized document does not belong to the assessee? - As primarily argued mandatory satisfaction note, which is to be recorded by the A.O. of the searched party during the course of the assessment proceedings of the search party for assuming jurisdiction u/s 153C by the A.O. of the assessee, was not recorded - HELD THAT:- As DR could not controvert the factual submissions of the assessee. He could not produce proof to demonstrate that the satisfaction has been recorded by the A.O. of the searched party. A.O. who is having the jurisdiction of the searched party, has admittedly not recorded satisfaction note, as mandated by law enabling the A.O. of the assessee to assume jurisdiction u/s 153C - we quash the assessment orders for AY 2007-08 and 2008-09 and dismiss all the appeals filed by the Revenue. Decided in favour of assessee.
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