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2018 (2) TMI 62

Assessment u/s 153C - existence of satisfaction note - Held that:- The Special Leave Petition is dismissed. HC order confirmed [2017 (7) TMI 539 - DELHI HIGH COURT] wherein held while the documents may ‘pertain to’ the Assessee, but in the context explained above, they cannot be presumed to be documents that ‘belonged to’ the searched person. Consequently, even with regard to these documents, the jurisdictional requirement under Section 153 C (1) of the AO of the searched person having to be satisfied that the said documents do not belong to searched person but to the Assessee, has not been fulfilled. - Decided in favour of assessee.


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