Dismissing the petition the Court held that satisfaction under s. 153C would be in the realm of subjective satisfaction of the concerned AO. The sufficiency or correctness of the documents ar material handed over by the other AO to him also could not be gone into by the Court at the stage of admission of writ proceedings. Writ petition was dismissed. (AY. 2012-13)
Raju Bhupendra Desai v. ITO (2021) 323 CTR 446 / 207 DTR 129 (Guj.)(HC).Editorial: SLP of assessee dismissed, Raju Bhupendra Desai v. ITO( 2022) 443 ITR 6 (St)(SC)
S. 153C : Assessment-Income of any other person-Search-Notice was issued after considering the objections-Alternative remedy is available-Writ is not maintainable. [Art. 226]