https://www.taxtmi.com/caselaws?id=764121 ITAT Delhi held that assessment under section 153C was invalid due to mechanical recording of satisfaction without proper application of mind. The AO's satisfaction note was nearly identical to that of the searched person's AO, constituting a carbon copy approach. The tribunal found that seized documents were not properly examined to establish their relevance to the assessee's income for specific assessment years. Following Delhi HC precedent in Canyon Financial Services Ltd., proceedings initiated without genuine satisfaction and rational connection between seized material and undisclosed income cannot be sustained. Appeal decided in favor of assessee. en-us Tue, 31 Dec 2024 00:00:00 +0530 Thu, 02 Jan 2025 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764121 ITAT Delhi held that assessment under section 153C was invalid due to mechanical recording of satisfaction without proper application of mind. The AO's satisfaction note was nearly identical to that of the searched person's AO, constituting a carbon copy approach. The tribunal found that seized documents were not properly examined to establish their relevance to the assessee's income for specific assessment years. Following Delhi HC precedent in Canyon Financial Services Ltd., proceedings initiated without genuine satisfaction and rational connection between seized material and undisclosed income cannot be sustained. Appeal decided in favor of assessee. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764121