https://www.taxtmi.com/caselaws?id=752852 ITAT Delhi held that assessments made under Section 144 r.w.s. 142(1) were void ab initio as they should have been conducted under Section 153C. The court established that satisfaction note recording is the first step for Section 153C proceedings, and the date of satisfaction determines the relevant assessment period. Following RRJ Securities Ltd. precedent, assessments for AY 2003-04 and 2004-05 were deemed outside Section 153C scope, while AY 2012-13 assessment was invalid for failing to invoke proper Section 153C procedures despite satisfaction note being recorded. en-us Tue, 02 Jan 2024 00:00:00 +0530 Sat, 18 May 2024 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752852 ITAT Delhi held that assessments made under Section 144 r.w.s. 142(1) were void ab initio as they should have been conducted under Section 153C. The court established that satisfaction note recording is the first step for Section 153C proceedings, and the date of satisfaction determines the relevant assessment period. Following RRJ Securities Ltd. precedent, assessments for AY 2003-04 and 2004-05 were deemed outside Section 153C scope, while AY 2012-13 assessment was invalid for failing to invoke proper Section 153C procedures despite satisfaction note being recorded. Case-Laws Income Tax Tue, 02 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752852