PCIT v. G. Lakshmi Aruna (Smt) (2024) 297 Taxman 396 (SC) Editorial: PCIT v. G. Lakshmi Aruna (2023) 150 taxmann.com 107 /333 CTR 257/225 DTR 417 (Karn)(HC)

S. 153C : Assessment-Income of any other person-Recording of satisfaction is mandatory by the Assessing Officer of searched person-Order of High Court affirming the order of Tribunal is affirmed-SLP of Revenue is dismissed. [S. 143(3)]

Assessing Officer of searched person issued notice under section 153C against assessee for assessment years 2005-06 to 2010-11 and a notice under section 143(3) for assessment year 2011-12. Tribunal held that there was no satisfaction recorded by Assessing Officer of searched person, which is mandatorily required for issuing a notice under section 153C. High Court held that recording of satisfaction note is pre-requisite and same must be prepared by Assessing Officer before he transmits record to other Assessing Officer who has jurisdiction over such other person under section 153C and since in instant case satisfaction note was not recorded by Assessing Officer of searched person, Tribunal had rightly quashed assessment on account of lack of jurisdiction. SLP of Revenue is dismissed. (AY. 2011-12)