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A consolidated satisfaction note was prepared for multiple assessment years instead of separate notes, rendering the assessment proceedings u/s 153C invalid. The ITAT held that without a separate satisfaction note establishing the seized materials' relevance to the assessee, no addition could be made without resorting to Sections 147/148 or 153C. As the twin conditions for invoking Section 263 were not met, the ITAT quashed the assessment framed u/s 153C read with Section 143(3), deciding in favor of the assessee.
A consolidated satisfaction note was prepared for multiple assessment years instead of separate notes, rendering the assessment proceedings u/s 153C invalid. The ITAT held that without a separate satisfaction note establishing the seized materials' relevance to the assessee, no addition could be made without resorting to Sections 147/148 or 153C. As the twin conditions for invoking Section 263 were not met, the ITAT quashed the assessment framed u/s 153C read with Section 143(3), deciding in favor of the assessee.
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