https://www.taxtmi.com/caselaws?id=756811 The ITAT Mumbai quashed assessment orders under section 153C for assessment years 2008-09 and 2009-10, ruling that the AO failed to record valid satisfaction before issuing notices. The satisfaction note did not establish that seized money, valuables, or documents belonged to or related to the assessee, which is a jurisdictional requirement under section 153C. Following SC precedent in Super Mall Pvt Ltd, the tribunal held the AO lacked jurisdiction to frame assessments. Consequently, penalties under section 271AAA were also quashed as the foundational assessment was invalid. The assessee's appeals were allowed. en-us Tue, 30 Jan 2024 00:00:00 +0530 Fri, 09 Aug 2024 10:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756811 The ITAT Mumbai quashed assessment orders under section 153C for assessment years 2008-09 and 2009-10, ruling that the AO failed to record valid satisfaction before issuing notices. The satisfaction note did not establish that seized money, valuables, or documents belonged to or related to the assessee, which is a jurisdictional requirement under section 153C. Following SC precedent in Super Mall Pvt Ltd, the tribunal held the AO lacked jurisdiction to frame assessments. Consequently, penalties under section 271AAA were also quashed as the foundational assessment was invalid. The assessee's appeals were allowed. Case-Laws Income Tax Tue, 30 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756811