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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.
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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