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The ITAT held that initiation of proceedings u/s 153C requires the Assessing Officer to obtain a certificate verifying the veracity and reliability of the record. In the absence of such compliance and a certificate u/s 65B of the Evidence Act, 1872, which is mandatory, the action of the Assessing Officer to initiate proceedings u/s 153C was improper. Accordingly, the relevant ground raised by the assessee was allowed.
The ITAT held that initiation of proceedings u/s 153C requires the Assessing Officer to obtain a certificate verifying the veracity and reliability of the record. In the absence of such compliance and a certificate u/s 65B of the Evidence Act, 1872, which is mandatory, the action of the Assessing Officer to initiate proceedings u/s 153C was improper. Accordingly, the relevant ground raised by the assessee was allowed.
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