https://www.taxtmi.com/caselaws?id=773266 ITAT Ahmedabad held that assessment under section 153C was invalid due to delayed recording of satisfaction by the AO of the searched person. The tribunal ruled it had inherent powers under section 254(2) to entertain new grounds challenging jurisdictional validity. Following SC precedents in Calcutta Knitwears and Gujarat HC decision in Anilkumar Gopikishan Agrawal, the satisfaction was not recorded within reasonable time limits prescribed after conclusion of search proceedings. Consequently, the AO's assumption of jurisdiction under section 153C was deemed invalid, making the resultant assessment unsustainable in law. en-us Thu, 15 May 2025 00:00:00 +0530 Mon, 02 Mar 2026 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773266 ITAT Ahmedabad held that assessment under section 153C was invalid due to delayed recording of satisfaction by the AO of the searched person. The tribunal ruled it had inherent powers under section 254(2) to entertain new grounds challenging jurisdictional validity. Following SC precedents in Calcutta Knitwears and Gujarat HC decision in Anilkumar Gopikishan Agrawal, the satisfaction was not recorded within reasonable time limits prescribed after conclusion of search proceedings. Consequently, the AO's assumption of jurisdiction under section 153C was deemed invalid, making the resultant assessment unsustainable in law. Case-Laws Income Tax Thu, 15 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773266