The AO initiated assessments under section 153C r.w.s. 143(3) based on documents seized during a search on the Chetak Group. The assessee argued that the AO failed to record a separate satisfaction note for each assessment year, as required under law. The ITAT held that satisfaction under section 153C must be recorded separately for each year. Since a combined satisfaction note was prepared for multiple years, the ITAT held the proceedings as defective and quashed the notices under section 153C as well as assessments for AY 2014-15 and 2015-16. (AY. 2014-15, 2016-17)
Anjana Construction v. ACIT (2025) 128 ITR 148 (Jodhpur)(Trib.)
S. 153C: Assessment-Income of any other person -Search-A satisfaction note is required to be recorded under section 153C for each assessment year-A consolidated satisfaction note recorded for different assessment years would vitiate entire assessment proceedings [S. 132, 153A]
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