https://www.taxtmi.com/caselaws?id=753991 The ITAT Delhi held that assessments under sections 153A/153C require the AO to record satisfaction notes for each assessment year and refer to specific seized/incriminating materials to justify proceedings. Since the Department failed to produce any seized/incriminating materials that influenced the additions and the assessment orders were not based on materials found during search operations, the additions were unsustainable. Following the SC precedent in PCIT v. Abhisar Buildwell Pvt. Ltd. and consistent with a coordinate bench decision, the ITAT deleted the disputed additions and allowed the assessee's appeal. en-us Wed, 12 Jun 2024 00:00:00 +0530 Thu, 13 Jun 2024 21:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753991 The ITAT Delhi held that assessments under sections 153A/153C require the AO to record satisfaction notes for each assessment year and refer to specific seized/incriminating materials to justify proceedings. Since the Department failed to produce any seized/incriminating materials that influenced the additions and the assessment orders were not based on materials found during search operations, the additions were unsustainable. Following the SC precedent in PCIT v. Abhisar Buildwell Pvt. Ltd. and consistent with a coordinate bench decision, the ITAT deleted the disputed additions and allowed the assessee's appeal. Case-Laws Income Tax Wed, 12 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753991