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ITAT held that the assessment proceedings under section 153C for Assessment Years 2011-12 and 2012-13 are barred by limitation. The 'satisfaction note' was deemed legally insufficient as it failed to demonstrate proper application of mind, specify searched documents against each assessment year, and provide tangible information justifying invocation of section 153C. The tribunal found the jurisdictional assessment order fundamentally defective, lacking substantive reasoning to support cross-jurisdictional assessment. Consequently, the notice and subsequent assessment order were quashed, and the assessee's appeal was allowed, effectively invalidating the tax department's attempted reassessment.
ITAT held that the assessment proceedings under section 153C for Assessment Years 2011-12 and 2012-13 are barred by limitation. The 'satisfaction note' was deemed legally insufficient as it failed to demonstrate proper application of mind, specify searched documents against each assessment year, and provide tangible information justifying invocation of section 153C. The tribunal found the jurisdictional assessment order fundamentally defective, lacking substantive reasoning to support cross-jurisdictional assessment. Consequently, the notice and subsequent assessment order were quashed, and the assessee's appeal was allowed, effectively invalidating the tax department's attempted reassessment.
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