Dismissing the appeal of the Revenue the Court held that satisfaction note is required to be recorded under section 153C for each assessment year and in the impugned proceedings, a consolidated satisfaction note has been recorded for different assessment years, which also vitiates the entire assessment proceedings. In view of all these findings, it is said that the appeals do not have any substance for seeking intervention by the Court. No substantial question of law. (AY. 2012-13 to 2018-19)
Dy. CIT v. Sunil Kumar Sharma (2024) 159 taxmann.com 179 (Karn)(HC) Editorial : CIT (Appeals) v. Sunil Kumar Sharma (2024) 300 Taxman 601 (SC)
S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction note is required to be recorded under section 153C for each assessment year-Consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings.[S. 132, 260A]
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