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2017 (5) TMI 113 - AT - Income TaxValidity of acquiring the jurisdiction by the Assessing Officer u/s 153C - absence of satisfaction note - Held that:- decide this issue in favour of the assessee by holding that in absence of any ‘satisfaction’ noted by the Assessing Officer of the searched person, the initiation of the impugned proceedings u/s 153C is invalid and accordingly, all the assessment orders for the impugned assessment years are hereby quashed as void-ab-initio. The said finding would be applicable in all the years, because the jurisdiction u/s 153C has been acquired only on the basis of same ‘satisfaction note’ as incorporated above which has been recorded by the Assessing Officer of the assessee and not by the Assessing Officer of the searched person during the course of the assessment or search proceedings of the searched person. Accordingly, for all the years the assessment orders are quashed. - Decided in favour of assessee
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