ITO v. Forever Bodycare Industries.(2025) 482 ITR 285/ 173 taxmann.com 912 (SC)

S. 153C : Assessment-Income of any other person-Search-No incriminating material-Satisfaction notes had not recorded any reasons-SLP of revenue dismissed on account of delay and also on merits. [Art. 136]

High Court quashed notices issued under section 153C of the Income-tax Act, 1961, holding that no incriminating material had been gathered or obtained and that the satisfaction notes of the jurisdictional Assessing Officers had failed to record any reasons to show that the material discovered and pertaining to a particular assessment year was likely to “have a bearing on the determination of the total income” for the year which was sought to be abated or reopened in terms of the notices, and that none of the satisfaction notes had recorded any reasons of how that material was likely to materially influence the computation of income for those assessment years. SLP dismissed on account of delay and also on merits. (AY. 2013-14 to 2020-21)

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