Bhagwandas Rupchand Parwani v. ACIT (2024) 470 ITR 590 / 160 taxmann.com 7 (Guj) (HC)

S. 153C : Assessment-Income of any other person-Search-Recording of satisfaction-Copy in verbatim of satisfaction note of Assessing Officer of searched person-No jurisdictional error-Recording of satisfaction is valid. [S. 132, Art.226]

Held that while initiating proceedings under section 153C, it is sufficient for Assessing Officer to note in satisfaction note that documents seized from searched person belonged to other person. Fact that satisfaction note drawn by Assessing Officer of assessee was carbon copy of note of Assessing Officer of searched person, would not be reason to reject satisfaction note saying that Assessing Officer of assessee did not record his independent satisfaction. Legal requirement is satisfied.  (AY. 2014-15)

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