Dy. CIT v. Sushil Tyagi (2024) 115 ITR 90 (SN)(Delhi)(Trib)

S. 153A : Assessment-Search-Additional ground admitted-Seized document related to third party-Proceedings to be transferred to Assessing Officer of third party-No satisfaction note prepared and no proceeding under Sectionb153C is initiated-Employee of searched company-Proceedings under section 153A is invalid. [S. 132, 153C]

Held that when the seized document related to the third party, proceedings to be  transferred to Assessing Officer of third party. On facts neither satisfaction note prepared and no proceeding under Sectionb153C is initiated   merely because the  assessee is employee of searched company, proceedings under section 153A is invalid. (AY. 2011-12, 2016-17, 2017-18)

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