https://www.taxtmi.com/caselaws?id=759030 ITAT Delhi held that proceedings under section 153C were invalid due to improper recording of satisfaction by the AO. The AO failed to record how seized documents had bearing on determination of total income for six assessment years preceding the search year. Following Saksham Commodities Ltd precedent, the tribunal found the satisfaction note did not comply with statutory requirements as it lacked assessment of potential impact on undeclared income. The proceedings were deemed without proper jurisdiction and the assessee's ground was allowed. en-us Fri, 30 Aug 2024 00:00:00 +0530 Sat, 21 Sep 2024 12:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759030 ITAT Delhi held that proceedings under section 153C were invalid due to improper recording of satisfaction by the AO. The AO failed to record how seized documents had bearing on determination of total income for six assessment years preceding the search year. Following Saksham Commodities Ltd precedent, the tribunal found the satisfaction note did not comply with statutory requirements as it lacked assessment of potential impact on undeclared income. The proceedings were deemed without proper jurisdiction and the assessee's ground was allowed. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759030