https://www.taxtmi.com/caselaws?id=770804 ITAT Delhi held the assessment order under section 153C void ab-initio as the AO failed to record proper satisfaction note before initiating proceedings, following SC precedent in Super Mall case. The tribunal deleted the addition and set aside the impugned order. However, regarding share application money of Rs. 2.24 crores, ITAT found the surrender by the individual was genuine despite subsequent retraction, as evidenced by documentary proof. The tribunal upheld the addition of Rs. 2.24 crores on substantive grounds, finding the genuineness and source unexplained. en-us Fri, 25 Apr 2025 00:00:00 +0530 Fri, 16 May 2025 08:40:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770804 ITAT Delhi held the assessment order under section 153C void ab-initio as the AO failed to record proper satisfaction note before initiating proceedings, following SC precedent in Super Mall case. The tribunal deleted the addition and set aside the impugned order. However, regarding share application money of Rs. 2.24 crores, ITAT found the surrender by the individual was genuine despite subsequent retraction, as evidenced by documentary proof. The tribunal upheld the addition of Rs. 2.24 crores on substantive grounds, finding the genuineness and source unexplained. Case-Laws Income Tax Fri, 25 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770804