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The ITAT allowed the assessee's appeal, holding that the assumption of jurisdiction u/s 153C of the Income Tax Act by the Assessing Officer was vitiated due to a lack of proper 'satisfaction note'. The 'satisfaction note' lacked tangible and descriptive information, indicating a lack of application of mind. Consequently, the notice issued u/s 153C and the consequent assessment order were quashed. Additionally, regarding the valuation of a property, the ITAT accepted the assessee's contention and the District Valuation Officer's report, which was closer to the declared sale consideration. The significant difference between the sale consideration mentioned in the Agreement to Sale and the Sale Deed was deemed unconceivable and contrary to the estimated market value. The assessee's declared sale consideration was upheld in the absence of any contrary inquiry by the Revenue.
The ITAT allowed the assessee's appeal, holding that the assumption of jurisdiction u/s 153C of the Income Tax Act by the Assessing Officer was vitiated due to a lack of proper 'satisfaction note'. The 'satisfaction note' lacked tangible and descriptive information, indicating a lack of application of mind. Consequently, the notice issued u/s 153C and the consequent assessment order were quashed. Additionally, regarding the valuation of a property, the ITAT accepted the assessee's contention and the District Valuation Officer's report, which was closer to the declared sale consideration. The significant difference between the sale consideration mentioned in the Agreement to Sale and the Sale Deed was deemed unconceivable and contrary to the estimated market value. The assessee's declared sale consideration was upheld in the absence of any contrary inquiry by the Revenue.
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