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Income Tax - Highlights / Catch Notes

Home Highlights November 2020 Year 2020 This

Assessment u/s 153A - Need for spelling out ‘Satisfaction note’ ...


AO's Jurisdiction u/s 153C Invalid Without Valid Satisfaction Note for 2014-15 Assessment Year.

November 6, 2020

Case Laws     Income Tax     AT

Assessment u/s 153A - Need for spelling out ‘Satisfaction note’ - the ld. CIT(A) while adjudicating the legal issue of the validity of the satisfaction note prepared by the AO to invoke 153C against the assessee foundation, cannot resort to post mortem and resurrect a bad satisfaction note because AO could not have usurped the jurisdiction u/s 153C without preparing a valid Satisfaction Note and therefore AO’s action to invoke the jurisdiction u/s 153C in respect of AY 2014-15 was ab-initio void - AT

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