Allowing the petition of the assesse the Court held that; before issue of notice u/s 153C the AO is required to arrive at a conclusive satisfaction that documents belongs to a person other than searched person searched .Mere use of word “ satisfaction “ or “I am satisfied “ in order or note would not meet requirement of concept of satisfaction as used in S. 153C of the Act .Accordingly the notice u/s 153C was quashed .( AY. 2006 -07 to 2011-12 )
Pepsi Foods ( P) Ltd v. ACIT ( 2015) 231 Taxman 58/ 162 DTR 129 ( Delhi ) (HC) Editorial: SLP of revenue was dismissed , ACIT v. Pepsi Foods ( P) Ltd ( 2018) 252 Taxman 372 (SC)
S. 153C: Assessment- Income of any other person- Search and seizure – AO is required to arrive at a conclusive satisfaction that documents belongs to a person other than searched person [ S. 132(4A)(i), 158BD,292C ]