https://www.taxtmi.com/caselaws?id=463770 Initiation of proceedings under s.153C for six assessment years was challenged on the ground that the jurisdictional AO's satisfaction note did not demonstrate existence of incriminating material relatable to the impugned years. The HC held that the satisfaction note, though referring to material for certain years, ex facie disclosed no incriminating material for the relevant years and did not record reasons showing how the material had a bearing on determination of total income of the "other person" for those years. Relying on its settled precedent that mere recovery of any material in search does not authorise reassessment of all six preceding years absent year-specific incriminating material, the HC quashed the s.153C notices and all consequential proceedings. en-us Wed, 22 May 2024 00:00:00 +0530 Fri, 19 Dec 2025 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463770 Initiation of proceedings under s.153C for six assessment years was challenged on the ground that the jurisdictional AO's satisfaction note did not demonstrate existence of incriminating material relatable to the impugned years. The HC held that the satisfaction note, though referring to material for certain years, ex facie disclosed no incriminating material for the relevant years and did not record reasons showing how the material had a bearing on determination of total income of the "other person" for those years. Relying on its settled precedent that mere recovery of any material in search does not authorise reassessment of all six preceding years absent year-specific incriminating material, the HC quashed the s.153C notices and all consequential proceedings. Case-Laws Income Tax Wed, 22 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463770