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Assessment u/s 153C - recording of satisfaction - From the plain reading of the the Circular it is noticed in para 4 that even if the AO of the searched person and the other person is one and the same, then also AO is required to record the satisfaction, as held by the various Courts. In the instant case, no such material has been brought before us by the ld. DR - Since the satisfaction was not recorded by the Assessing Officer before issue of notice U/s. 153C we are of the considered view that the order passed by the Ld. CIT(A) U/s. 153C of the Act deserves to be set aside for all the impugned assessment years - AT
Assessment u/s 153C - recording of satisfaction - From the plain reading of the the Circular it is noticed in para 4 that even if the AO of the searched person and the other person is one and the same, then also AO is required to record the satisfaction, as held by the various Courts. In the instant case, no such material has been brought before us by the ld. DR - Since the satisfaction was not recorded by the Assessing Officer before issue of notice U/s. 153C we are of the considered view that the order passed by the Ld. CIT(A) U/s. 153C of the Act deserves to be set aside for all the impugned assessment years - AT
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