Petitioner challenged notice under Section 153C for Assessment year 2017-18 on ground that satisfaction was not recorded at any permissible stage and, in any case, was not recorded \u201cimmediately after\u201d completion of searched person\u2019s assessment. Department attributed the delay to COVID-19 and the Faceless Assessment Scheme. It was noted that though the Assessing Officer had an opportunity to record a satisfaction note at two stages as specified in Circular No. 24\/2015 but same was not done. Further, search was conducted on 15-10-2019, searched person\u2019s assessment was completed in August 2021. Satisfaction note was recorded on 6-6-2023 by the Assessing Officer of the searched person, which was forwarded to the Assessing Officer of petitioner, who in turn recorded a satisfaction note on 17-10-2023. Since there was a delay of 22 months in recording the satisfaction note, which ran contrary to the decision in CIT v. Calcutta Knitwears\u00a0[2014] 43 taxmann.com 446\/223\u00a0Taxman\u00a0115\/362 ITR 673 (SC)\u00a0as well as provision ‘(c)’ of Circular No.24\/2015, the notice under Section 153C was quashed. (AY. 2017-18)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction was recorded four years after search and two years after assessment of searched person-Notice was quashed and set aside. [S.132, 153A, Art. 226] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_feature_clip_id":0,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_post_was_ever_published":false},"categories":[21],"tags":[],"class_list":["post-64179","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-gH9","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/64179","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=64179"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/64179\/revisions"}],"predecessor-version":[{"id":64180,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/64179\/revisions\/64180"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=64179"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=64179"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=64179"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}