https://www.taxtmi.com/caselaws?id=762318 ITAT Delhi quashed assessment proceedings initiated under Section 153C, ruling the assumption of jurisdiction void ab-initio. The court found the satisfaction note factually incorrect as no search was conducted on the assessee. The AO failed to provide seized material or investigation findings to support allegations that the assessee's exempt long-term capital gains from share sales were bogus. The satisfaction note merely expressed intent to examine LTCG without drawing conclusions based on evidence. The tribunal held that Section 153C proceedings cannot be initiated solely to examine particular aspects without prior satisfaction based on concrete findings. The assessee's appeal was allowed. en-us Tue, 26 Nov 2024 00:00:00 +0530 Fri, 29 Nov 2024 08:16:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762318 ITAT Delhi quashed assessment proceedings initiated under Section 153C, ruling the assumption of jurisdiction void ab-initio. The court found the satisfaction note factually incorrect as no search was conducted on the assessee. The AO failed to provide seized material or investigation findings to support allegations that the assessee's exempt long-term capital gains from share sales were bogus. The satisfaction note merely expressed intent to examine LTCG without drawing conclusions based on evidence. The tribunal held that Section 153C proceedings cannot be initiated solely to examine particular aspects without prior satisfaction based on concrete findings. The assessee's appeal was allowed. Case-Laws Income Tax Tue, 26 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762318