https://www.taxtmi.com/caselaws?id=762604 ITAT Delhi held that the satisfaction note under section 153C lacked jurisdiction due to being vague and unintelligible. The court ruled that perfunctory satisfaction without tangible information and application of mind cannot confer assessment jurisdiction on non-searched persons. The notice and assessment order under section 153C were quashed. Additionally, regarding property valuation, the tribunal found the DVO report supporting the assessee's declared sale consideration was more credible than an unsigned agreement copy. The difference between agreement and sale deed amounts was deemed unconceivable given the DVO's market valuation. Assessee's appeal was allowed. en-us Mon, 25 Nov 2024 00:00:00 +0530 Wed, 04 Dec 2024 08:44:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762604 ITAT Delhi held that the satisfaction note under section 153C lacked jurisdiction due to being vague and unintelligible. The court ruled that perfunctory satisfaction without tangible information and application of mind cannot confer assessment jurisdiction on non-searched persons. The notice and assessment order under section 153C were quashed. Additionally, regarding property valuation, the tribunal found the DVO report supporting the assessee's declared sale consideration was more credible than an unsigned agreement copy. The difference between agreement and sale deed amounts was deemed unconceivable given the DVO's market valuation. Assessee's appeal was allowed. Case-Laws Income Tax Mon, 25 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762604