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ITAT quashed assessment orders under section 153C for assessment years 2016-17 and 2017-18, ruling that the Assessing Officer lacked jurisdiction over the assessee whose documents were found during search operations. The tribunal found that satisfaction regarding the searched person was recorded on 06.09.2018, while satisfaction for the other person was recorded on 03.09.2018, creating jurisdictional deficiency. The satisfaction dated 03.09.2018 was deemed legally invalid without proper foundational satisfaction from the searched person's AO. Regarding undisclosed business income from on-money receipts on property sales, ITAT directed estimation of 25% profit on total gross receipts instead of treating entire amounts as unaccounted sales, recognizing legitimate business expenditure against unaccounted receipts and deleting balance additions.
ITAT quashed assessment orders under section 153C for assessment years 2016-17 and 2017-18, ruling that the Assessing Officer lacked jurisdiction over the assessee whose documents were found during search operations. The tribunal found that satisfaction regarding the searched person was recorded on 06.09.2018, while satisfaction for the other person was recorded on 03.09.2018, creating jurisdictional deficiency. The satisfaction dated 03.09.2018 was deemed legally invalid without proper foundational satisfaction from the searched person's AO. Regarding undisclosed business income from on-money receipts on property sales, ITAT directed estimation of 25% profit on total gross receipts instead of treating entire amounts as unaccounted sales, recognizing legitimate business expenditure against unaccounted receipts and deleting balance additions.
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