https://www.taxtmi.com/caselaws?id=779007 ITAT, DELHI-AT set aside final assessments: a single consolidated satisfaction note for multiple distinct assessees/years was invalid, as s.153C requires separate, year-wise satisfaction and analysis of seized material; no adverse assessment could be sustained for years not shown to relate to the incriminating material. The assessee, a foreign non-resident eligible under s.144C(15)(b), was entitled to a mandatory draft assessment under s.144C(1); the AO failed to issue it, vitiating the final orders. The Tribunal upheld the CIT(A) and dismissed the Revenue's grounds. en-us Fri, 19 Sep 2025 00:00:00 +0530 Fri, 26 Sep 2025 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779007 ITAT, DELHI-AT set aside final assessments: a single consolidated satisfaction note for multiple distinct assessees/years was invalid, as s.153C requires separate, year-wise satisfaction and analysis of seized material; no adverse assessment could be sustained for years not shown to relate to the incriminating material. The assessee, a foreign non-resident eligible under s.144C(15)(b), was entitled to a mandatory draft assessment under s.144C(1); the AO failed to issue it, vitiating the final orders. The Tribunal upheld the CIT(A) and dismissed the Revenue's grounds. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779007