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2017 (7) TMI 738 - HC - Income TaxValidity of proceedings under Section 153-C - satisfaction note - Held that:- In the present case, the AO of the searched person and the other person (the Assessee) was the same. In similar circumstances, the Court has recently in Ganpati Fincap Services Pvt Ltd. v. CIT [2017 (5) TMI 1425 - DELHI HIGH COURT] held that there do not have to be two separate satisfaction notes prepared by the AO of the searched person even where he is also the AO of the other person. In such event, the AO need make only one satisfaction note. That satisfaction note is qua the other person. In that view of the matter, the impugned order of the ITAT which proceeds to invalidate the proceedings under Section 153C of the Act only for the reason that the AO of the searched who was also that of the Assessee, did not record a separate satisfaction note cannot be sustained in law. - Decided in favour of revenue
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