TMI BlogValidity assessment proceedings u/s 153C - recording of satisfaction - The ITAT examined the language of...Validity assessment proceedings u/s 153C - recording of satisfaction - The ITAT examined the language of Section 153C and referenced the judgment in Ganpati Fincap Services P. Ltd & Ors v. Commissioner of Income Tax. It concluded that only one satisfaction note is required, even if the Assessing Officer of the searched person and the other person is the same. The satisfaction note must confirm that the seized documents belong to the other person, fulfilling the requirements of Section 153C. - It was clarified that the failure of the Assessing Officer of the searched person to make a note in the file of the searched person after transmitting documents to the Assessing Officer of the other person does not invalidate the proceedings under Section 153C. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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