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ITAT allowed the appeal, holding the reassessment proceedings under s.153C invalid and the additions under s.69 deleted. The Tribunal found the AO's satisfaction note to be a consolidated, non-year-specific record, failing the statutory requirement of distinct, contemporaneous satisfaction relatable to each assessment year; such omnibus satisfaction vitiates jurisdiction and renders proceedings void ab initio. Further, the alleged incriminating material-a pen drive seized from a third party-was held to be a "dumb document": not seized from the assessee, not authenticated by the custodian, lacking year-wise nexus, corroborative bank or asset evidence, and denied by the assessee. In absence of independent corroboration, the additions were arbitrary and unsustainable.
ITAT allowed the appeal, holding the reassessment proceedings under s.153C invalid and the additions under s.69 deleted. The Tribunal found the AO's satisfaction note to be a consolidated, non-year-specific record, failing the statutory requirement of distinct, contemporaneous satisfaction relatable to each assessment year; such omnibus satisfaction vitiates jurisdiction and renders proceedings void ab initio. Further, the alleged incriminating material-a pen drive seized from a third party-was held to be a "dumb document": not seized from the assessee, not authenticated by the custodian, lacking year-wise nexus, corroborative bank or asset evidence, and denied by the assessee. In absence of independent corroboration, the additions were arbitrary and unsustainable.
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