https://www.taxtmi.com/caselaws?id=774234 ITAT Pune quashed assessment proceedings under section 153C for four assessment years due to jurisdictional defects. The AO incorrectly treated a survey under section 133A as a search action and issued notices under section 153A without proper satisfaction notes. The seized work order did not belong to the assessee but merely pertained to them. Since the search, satisfaction note, and notices were all issued before June 1, 2015, the pre-amendment provisions applied requiring documents to "belong to" rather than "pertain to" the other person. The assessment lacked proper jurisdiction and approval under section 153D was granted without application of mind. en-us Wed, 25 Jun 2025 00:00:00 +0530 Sat, 05 Jul 2025 08:47:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774234 ITAT Pune quashed assessment proceedings under section 153C for four assessment years due to jurisdictional defects. The AO incorrectly treated a survey under section 133A as a search action and issued notices under section 153A without proper satisfaction notes. The seized work order did not belong to the assessee but merely pertained to them. Since the search, satisfaction note, and notices were all issued before June 1, 2015, the pre-amendment provisions applied requiring documents to "belong to" rather than "pertain to" the other person. The assessment lacked proper jurisdiction and approval under section 153D was granted without application of mind. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774234