https://www.taxtmi.com/highlights?id=59030 Validity of initiation of proceedings u/s 153C - validity of satisfaction note - it is the duty of the AO to apply his mind and should consciously and mandatorily state in the satisfaction note that the seized documents belong to “other person”. Without recording such a satisfaction, it cannot be presumed that the seized materials belong to “other persons”, in which case the AO could not have initiated proceedings against the “other persons” u/s 153C of the Act. - AT en-us Tue, 03 Aug 2021 15:59:42 +0530 Tue, 03 Aug 2021 15:59:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=59030 Validity of initiation of proceedings u/s 153C - validity of satisfaction note - it is the duty of the AO to apply his mind and should consciously and mandatorily state in the satisfaction note that the seized documents belong to “other person”. Without recording such a satisfaction, it cannot be presumed that the seized materials belong to “other persons”, in which case the AO could not have initiated proceedings against the “other persons” u/s 153C of the Act. - AT Highlights Income Tax Tue, 03 Aug 2021 15:59:42 +0530 https://www.taxtmi.com/highlights?id=59030