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ITAT held that initiation of proceedings under s.153C against the assessee was invalid for failure to record the prerequisite satisfaction by the assessing officer of the searched third party; the sole basis for action was documents seized from that third party and the AO's satisfaction is a jurisdictional pre-condition. Revenue failed to produce the requisite satisfaction note despite repeated requests, and the process mandated by the CBDT guidance was not followed. Consequently, the assessment order framed under s.153C read with s.143(3) was quashed and the assessee's appeal was allowed.
ITAT held that initiation of proceedings under s.153C against the assessee was invalid for failure to record the prerequisite satisfaction by the assessing officer of the searched third party; the sole basis for action was documents seized from that third party and the AO's satisfaction is a jurisdictional pre-condition. Revenue failed to produce the requisite satisfaction note despite repeated requests, and the process mandated by the CBDT guidance was not followed. Consequently, the assessment order framed under s.153C read with s.143(3) was quashed and the assessee's appeal was allowed.
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