Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of ITAT affirms that the AO's invocation of s.153C was invalid because no individualized recorded satisfaction was made for each assessee and the purported satisfaction failed to specify assessment year(s), being a consolidated recording for 15 companies without AY-specific analysis of seized material; the tribunal upheld the lower authority's decision accordingly. The assessee qualifies as an 'eligible assessee' under s.144C(15)(b), thereby triggering the mandatory requirement under s.144C(1) to issue a draft assessment order, which the AO omitted. Consequently, the final assessment orders are vitiated for non-compliance with the statutory mandate to issue draft assessment orders and for improper application of s.153C.
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