Held that the satisfaction note makes no reference to the date of search and the assessment years and gives no description of the nature of the seized documents hence, said satisfaction note cannot be termed as a satisfaction note which could give power to the AO to assume jurisdiction under s. 153C. The Assessment order is invalid. No incriminating material was found addition is not justified. (AY. 2016-17)
ACIT v. Suntok Tea Co. (2024) 230 TTJ 681 / 241 DTR 204 / 38 NYPTTJ 836 (Guwahati) (Trib)
S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Neither reference to the date of search nor description of the nature of documents seized-Assessment order is invalid-No incriminating material was found-Addition is deleted. [S. 132]