https://www.taxtmi.com/caselaws?id=261577 The HC upheld the Tribunal's and CIT(A)'s orders quashing assessment proceedings under Section 153C, noting the AO failed to record satisfaction before initiating action against the assessee. The AO who conducted the search did not have jurisdiction over the assessee, and no seized papers belonged to the assessee. The court held that the AO under Section 153C must be satisfied that seized items relate to the assessee before issuing notice, similar to the requirement under Section 158BD. The AO having jurisdiction must independently verify facts before proceeding. The HC rejected the Department's argument of distinction between Sections 153C and 158BD, affirming the necessity of recorded satisfaction. The decision aligns with precedents from other HCs and was ruled in favor of the assessee. en-us Fri, 10 Jul 2015 00:00:00 +0530 Fri, 25 Jul 2025 14:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261577 The HC upheld the Tribunal's and CIT(A)'s orders quashing assessment proceedings under Section 153C, noting the AO failed to record satisfaction before initiating action against the assessee. The AO who conducted the search did not have jurisdiction over the assessee, and no seized papers belonged to the assessee. The court held that the AO under Section 153C must be satisfied that seized items relate to the assessee before issuing notice, similar to the requirement under Section 158BD. The AO having jurisdiction must independently verify facts before proceeding. The HC rejected the Department's argument of distinction between Sections 153C and 158BD, affirming the necessity of recorded satisfaction. The decision aligns with precedents from other HCs and was ruled in favor of the assessee. Case-Laws Income Tax Fri, 10 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261577