https://www.taxtmi.com/caselaws?id=762804 ITAT Delhi held that proceedings under section 153C were invalid for assessment years 2014-15 and 2015-16 as the satisfaction note was recorded on 30.09.2021, making only AY 2022-23 relevant based on the search date. For AYs 2016-17 to 2020-21, the satisfaction recorded failed to meet statutory requirements as it lacked reference to specific assessment years and seized materials with bearing on income determination. The satisfaction note was generic without establishing connection between discovered material and particular assessment years, contrary to Supreme Court precedent in Sinhgad Technical Education Society case. Appeal allowed. en-us Wed, 04 Dec 2024 00:00:00 +0530 Fri, 06 Dec 2024 15:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762804 ITAT Delhi held that proceedings under section 153C were invalid for assessment years 2014-15 and 2015-16 as the satisfaction note was recorded on 30.09.2021, making only AY 2022-23 relevant based on the search date. For AYs 2016-17 to 2020-21, the satisfaction recorded failed to meet statutory requirements as it lacked reference to specific assessment years and seized materials with bearing on income determination. The satisfaction note was generic without establishing connection between discovered material and particular assessment years, contrary to Supreme Court precedent in Sinhgad Technical Education Society case. Appeal allowed. Case-Laws Income Tax Wed, 04 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762804