https://www.taxtmi.com/caselaws?id=385779 Recording of satisfaction under section 153C is a jurisdictional precondition before notice can be issued against a person other than the searched person. Applying Calcutta Knitwears and CBDT Circular No. 24/2015, the ITAT Mumbai held that such satisfaction must be recorded even where the same officer handles both assessments. Because the Revenue failed to produce the satisfaction note despite direction, the assessment framed under section 143(3) read with section 153C was invalid and void ab initio. The additions made for computing book profit under section 115JB therefore became academic and infructuous. en-us Fri, 23 Aug 2019 00:00:00 +0530 Fri, 13 Sep 2019 06:00:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385779 Recording of satisfaction under section 153C is a jurisdictional precondition before notice can be issued against a person other than the searched person. Applying Calcutta Knitwears and CBDT Circular No. 24/2015, the ITAT Mumbai held that such satisfaction must be recorded even where the same officer handles both assessments. Because the Revenue failed to produce the satisfaction note despite direction, the assessment framed under section 143(3) read with section 153C was invalid and void ab initio. The additions made for computing book profit under section 115JB therefore became academic and infructuous. Case-Laws Income Tax Fri, 23 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385779