ACIT v. Kishore Kumar Sharma (2025) 307 Taxman 172 (SC) Editorial: Kishore Kumar Sharma v. ACIT [2025] 178 taxmann.com 315 (Delhi)(HC)

S. 153C : Assessment-Income of any other person-No incriminating material-SLP of revenue dismissed. [Art. 136]

 High Court held that where a satisfaction note issued by the Jurisdictional Assessing Officer of assessee did not refer to any incriminating material for the relevant assessment years, it was ex facie evident that no incriminating material had been found for the relevant assessment years. Further, the Jurisdictional Assessing Officer completely failed to record any reasons indicating how the material referred to by the Assessing Officer of the searched person could “have a bearing on the determination of total income of such other person”. Notice issued under section 153C and all consequential proceedings arising therefrom were to be quashed and set aside. SLP filed by the revenue against the order was dismissed. (AY. 2014-15 to 2020-21)

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