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The ITAT set aside the assessment framed u/s 153C due to the AO's failure to record a valid satisfaction note specifying escaped income for each assessment year, thereby invalidating jurisdiction. The AO's assumption of jurisdiction over A.Y. 2015-16 to 2021-22 was quashed as the satisfaction note was cryptic and did not demonstrate application of mind. The extended limitation period under section 153A was held inapplicable as the alleged escaped income was below Rs. 50 lakhs. The assessment related to A.Y. 2023-24 only, computed from the date incriminating material was received. The addition for alleged on-money payments was deleted for lack of evidence and denial of cross-examination. Enhancement under section 69 was also deleted as the source of funds was satisfactorily explained through sale proceeds and Capital Gains Account Scheme. Grounds challenging jurisdiction, addition, and enhancement were accordingly allowed.
The ITAT set aside the assessment framed u/s 153C due to the AO's failure to record a valid satisfaction note specifying escaped income for each assessment year, thereby invalidating jurisdiction. The AO's assumption of jurisdiction over A.Y. 2015-16 to 2021-22 was quashed as the satisfaction note was cryptic and did not demonstrate application of mind. The extended limitation period under section 153A was held inapplicable as the alleged escaped income was below Rs. 50 lakhs. The assessment related to A.Y. 2023-24 only, computed from the date incriminating material was received. The addition for alleged on-money payments was deleted for lack of evidence and denial of cross-examination. Enhancement under section 69 was also deleted as the source of funds was satisfactorily explained through sale proceeds and Capital Gains Account Scheme. Grounds challenging jurisdiction, addition, and enhancement were accordingly allowed.
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