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ITAT quashed assessment proceedings under section 153C for all four assessment years due to jurisdictional defects. The assessee was subject to survey under section 133A, not search action, yet the Assessing Officer issued notices under section 153A and obtained approval under section 153D without proper application of mind. The satisfaction note under section 153C was based on seized work order that did not "belong to" the assessee but merely "pertained to" the assessee. Since the search, satisfaction note, and notices were all issued prior to June 1, 2015, the pre-amendment provisions applied requiring documents to "belong to" rather than "pertain to" the other person. The assessment proceedings lacked proper jurisdiction and were held invalid.
ITAT quashed assessment proceedings under section 153C for all four assessment years due to jurisdictional defects. The assessee was subject to survey under section 133A, not search action, yet the Assessing Officer issued notices under section 153A and obtained approval under section 153D without proper application of mind. The satisfaction note under section 153C was based on seized work order that did not "belong to" the assessee but merely "pertained to" the assessee. Since the search, satisfaction note, and notices were all issued prior to June 1, 2015, the pre-amendment provisions applied requiring documents to "belong to" rather than "pertain to" the other person. The assessment proceedings lacked proper jurisdiction and were held invalid.
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