https://www.taxtmi.com/caselaws?id=198778 Initiation of proceedings under section 153C was treated as invalid because the satisfaction note was not recorded by the Assessing Officer of the searched person, but by the Assessing Officer of the other person. Recording satisfaction by the Assessing Officer of the searched person is a mandatory jurisdictional prerequisite for valid assumption of power under section 153C. As that foundational requirement was missing, the notice lacked jurisdiction and the consequential assessments could not be sustained. The Tribunal also noted the settled position and the CBDT litigation-withdrawal direction in cases where such satisfaction was absent, leading to quashing of the assessments. en-us Wed, 31 Aug 2016 00:00:00 +0530 Thu, 08 Feb 2018 21:19:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=198778 Initiation of proceedings under section 153C was treated as invalid because the satisfaction note was not recorded by the Assessing Officer of the searched person, but by the Assessing Officer of the other person. Recording satisfaction by the Assessing Officer of the searched person is a mandatory jurisdictional prerequisite for valid assumption of power under section 153C. As that foundational requirement was missing, the notice lacked jurisdiction and the consequential assessments could not be sustained. The Tribunal also noted the settled position and the CBDT litigation-withdrawal direction in cases where such satisfaction was absent, leading to quashing of the assessments. Case-Laws Income Tax Wed, 31 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=198778