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The ITAT set aside the assessment framed under section 153C, holding that the combined satisfaction note issued by the AO for multiple assessment years was invalid. The AO initiated proceedings based on documents seized during a search in a third-party case, but the issuance of a consolidated satisfaction note for different years contravened the statutory requirement to record separate satisfaction notes for each assessment year. Consequently, the CIT(A) rightly deleted the addition of Rs. 2,11,00,000, and the ITAT allowed the assessee's appeal, quashing the assessment proceedings initiated on the basis of the flawed combined satisfaction note.
The ITAT set aside the assessment framed under section 153C, holding that the combined satisfaction note issued by the AO for multiple assessment years was invalid. The AO initiated proceedings based on documents seized during a search in a third-party case, but the issuance of a consolidated satisfaction note for different years contravened the statutory requirement to record separate satisfaction notes for each assessment year. Consequently, the CIT(A) rightly deleted the addition of Rs. 2,11,00,000, and the ITAT allowed the assessee's appeal, quashing the assessment proceedings initiated on the basis of the flawed combined satisfaction note.
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