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ITAT held that jurisdictional assumption under Section 153C requires a substantive and descriptive satisfaction note. Mere perfunctory recording without tangible information and proper application of mind cannot confer assessment jurisdiction. The cryptic satisfaction note lacking specificity of searched documents/assets against respective assessment years renders the entire proceeding legally unsustainable. Consequently, the notice and consequent assessment order issued under Section 153C stand quashed, with the assessee's appeal being allowed.
ITAT held that jurisdictional assumption under Section 153C requires a substantive and descriptive satisfaction note. Mere perfunctory recording without tangible information and proper application of mind cannot confer assessment jurisdiction. The cryptic satisfaction note lacking specificity of searched documents/assets against respective assessment years renders the entire proceeding legally unsustainable. Consequently, the notice and consequent assessment order issued under Section 153C stand quashed, with the assessee's appeal being allowed.
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