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Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
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