Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT held that the Assessing Officer failed to comply with statutory prerequisites for initiating proceedings under s.153C: no independent satisfaction was recorded that seized documents did not belong to the person from whose possession they were seized, and no separate per-assessment-year satisfactions were recorded for the assessee, the AO having relied on a single consolidated satisfaction note covering multiple entities. Further, no draft assessment was issued as required by s.144C(1). Consequent assessments premised on the defective s.153C exercise were vitiated. ITAT upheld the CIT(A)'s order setting aside the final assessments and restored relief to the assessee.
ITAT held that the Assessing Officer failed to comply with statutory prerequisites for initiating proceedings under s.153C: no independent satisfaction was recorded that seized documents did not belong to the person from whose possession they were seized, and no separate per-assessment-year satisfactions were recorded for the assessee, the AO having relied on a single consolidated satisfaction note covering multiple entities. Further, no draft assessment was issued as required by s.144C(1). Consequent assessments premised on the defective s.153C exercise were vitiated. ITAT upheld the CIT(A)'s order setting aside the final assessments and restored relief to the assessee.
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