https://www.taxtmi.com/caselaws?id=754909 ITAT Delhi held that notice under Section 153C for assessment years 2011-12 and 2012-13 was invalid as these years fell outside the six-year limitation period computed from the financial year preceding the satisfaction recording date of 31.10.2018. The tribunal found the AO's satisfaction note vague and lacking logical reasoning, as seized materials failed to establish direct correlation with the relevant assessment years. The satisfaction note merely referenced seized documents without demonstrating how they belonged to the assessee or related to specific assessment years. Relying on SC precedent, ITAT quashed the entire reassessment proceedings under Section 153C, ruling the assumption of jurisdiction void ab initio. All appeals were allowed. en-us Fri, 21 Jun 2024 00:00:00 +0530 Wed, 03 Jul 2024 08:43:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754909 ITAT Delhi held that notice under Section 153C for assessment years 2011-12 and 2012-13 was invalid as these years fell outside the six-year limitation period computed from the financial year preceding the satisfaction recording date of 31.10.2018. The tribunal found the AO's satisfaction note vague and lacking logical reasoning, as seized materials failed to establish direct correlation with the relevant assessment years. The satisfaction note merely referenced seized documents without demonstrating how they belonged to the assessee or related to specific assessment years. Relying on SC precedent, ITAT quashed the entire reassessment proceedings under Section 153C, ruling the assumption of jurisdiction void ab initio. All appeals were allowed. Case-Laws Income Tax Fri, 21 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754909