https://www.taxtmi.com/caselaws?id=772768 ITAT Delhi allowed assessee's appeal, holding that assessment proceedings under section 153C were barred by limitation and lacked proper jurisdictional foundation. The satisfaction note dated 25.09.2018 established A.Y. 2018-19 as the relevant year, making A.Y. 2011-12 and 2012-13 fall outside the six-year limitation period. Additionally, the AO's satisfaction note was deemed cryptic and non-descript, failing to relate seized documents to specific assessment years or demonstrate proper application of mind. The court emphasized that section 153C requires nuanced reasoning and specific details linking seized materials to particular years, not perfunctory satisfaction notes. Consequently, the notice and assessment order under section 153C were quashed as legally vitiated. en-us Wed, 23 Apr 2025 00:00:00 +0530 Wed, 11 Jun 2025 18:41:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772768 ITAT Delhi allowed assessee's appeal, holding that assessment proceedings under section 153C were barred by limitation and lacked proper jurisdictional foundation. The satisfaction note dated 25.09.2018 established A.Y. 2018-19 as the relevant year, making A.Y. 2011-12 and 2012-13 fall outside the six-year limitation period. Additionally, the AO's satisfaction note was deemed cryptic and non-descript, failing to relate seized documents to specific assessment years or demonstrate proper application of mind. The court emphasized that section 153C requires nuanced reasoning and specific details linking seized materials to particular years, not perfunctory satisfaction notes. Consequently, the notice and assessment order under section 153C were quashed as legally vitiated. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772768