The satisfaction of the AO of the person in respect of whom the search was conducted to the effect that relates to a person other than person referred to in S.153A, is a sine qua non. In this case, no satisfaction note by the AO of the person in respect of whom the search was conducted was furnished by the Department despite categorical directions. Accordingly the order passed is held to be bad in law. (AY. 2008 -09)
Avalanche Reality P. Ltd. v. ACIT (2018) 68 ITR 79 (SN) (Indore)(Trib.)
S. 153C : Assessment-Income of any other person-Search and seizure—Satisfaction note is not available-Assessment is held to be bad in law. [S. 153A]