https://www.taxtmi.com/caselaws?id=774975 The ITAT Delhi quashed assessment proceedings u/s. 153C for AY 2015-16, ruling they were barred by limitation and lacked proper jurisdiction. The AO issued notice for seven years (AY 2013-14 to 2019-20) based on search date of 20.07.2018, but the tribunal held that limitation must be reckoned from satisfaction note date (10.06.2021), allowing only six years (AY 2016-17 to 2021-22). Following SC precedent in Jasjit Singh, proceedings for AY 2015-16 were time-barred. Additionally, the satisfaction note was found legally defective, being perfunctory without tangible information or proper application of mind. The AO failed to specify documents/assets against each assessment year, rendering the satisfaction note cryptic and non-descript. The tribunal held such defective satisfaction notes cannot confer jurisdiction u/s. 153C, making the entire proceedings null and void. Assessee's appeal was allowed. en-us Thu, 03 Jul 2025 00:00:00 +0530 Thu, 17 Jul 2025 08:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774975 The ITAT Delhi quashed assessment proceedings u/s. 153C for AY 2015-16, ruling they were barred by limitation and lacked proper jurisdiction. The AO issued notice for seven years (AY 2013-14 to 2019-20) based on search date of 20.07.2018, but the tribunal held that limitation must be reckoned from satisfaction note date (10.06.2021), allowing only six years (AY 2016-17 to 2021-22). Following SC precedent in Jasjit Singh, proceedings for AY 2015-16 were time-barred. Additionally, the satisfaction note was found legally defective, being perfunctory without tangible information or proper application of mind. The AO failed to specify documents/assets against each assessment year, rendering the satisfaction note cryptic and non-descript. The tribunal held such defective satisfaction notes cannot confer jurisdiction u/s. 153C, making the entire proceedings null and void. Assessee's appeal was allowed. Case-Laws Income Tax Thu, 03 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774975