https://www.taxtmi.com/highlights?id=92873 The ITAT affirmed the CIT(A)'s decision and dismissed all Revenue grounds, holding the impugned final assessment order vitiated. The AO's initiation under s.153C was invalid because a single consolidated satisfaction note for multiple distinct assessees and assessment years was recorded instead of distinct, year-wise satisfactions as mandated; seized material was not analyzed qua each assessment year. Applying the principle that incriminating material must be shown to pertain to a particular year, the Tribunal found non-compliance with ss.124-127 and s.153C. Further, because the assessee (a foreign non-resident and an "eligible assessee" under s.144C(15)(b)) did not receive a draft assessment as required by s.144C(1), the final order was vitiated and set aside. en-us Fri, 26 Sep 2025 08:26:58 +0530 Fri, 26 Sep 2025 08:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=92873 The ITAT affirmed the CIT(A)'s decision and dismissed all Revenue grounds, holding the impugned final assessment order vitiated. The AO's initiation under s.153C was invalid because a single consolidated satisfaction note for multiple distinct assessees and assessment years was recorded instead of distinct, year-wise satisfactions as mandated; seized material was not analyzed qua each assessment year. Applying the principle that incriminating material must be shown to pertain to a particular year, the Tribunal found non-compliance with ss.124-127 and s.153C. Further, because the assessee (a foreign non-resident and an "eligible assessee" under s.144C(15)(b)) did not receive a draft assessment as required by s.144C(1), the final order was vitiated and set aside. Highlights Income Tax Fri, 26 Sep 2025 08:26:58 +0530 https://www.taxtmi.com/highlights?id=92873