https://www.taxtmi.com/caselaws?id=781669 ITAT DELHI - AT held the assessment framed under s.143(3) invalid and quashed it, finding no notice under s.153C was issued. A search under s.132 yielded seized material and a satisfaction note was recorded after the relevant year, placing AY 2021-22 within the six-year block requiring initiation under s.153C read with s.153A. Because proceedings for AY 2021-22 were conducted under s.143(3) without the mandatory s.153C notice, the assessment lacked jurisdiction; the tribunal followed prevailing SC and HC precedents in reaching this conclusion. en-us Tue, 26 Aug 2025 00:00:00 +0530 Wed, 19 Nov 2025 08:52:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781669 ITAT DELHI - AT held the assessment framed under s.143(3) invalid and quashed it, finding no notice under s.153C was issued. A search under s.132 yielded seized material and a satisfaction note was recorded after the relevant year, placing AY 2021-22 within the six-year block requiring initiation under s.153C read with s.153A. Because proceedings for AY 2021-22 were conducted under s.143(3) without the mandatory s.153C notice, the assessment lacked jurisdiction; the tribunal followed prevailing SC and HC precedents in reaching this conclusion. Case-Laws Income Tax Tue, 26 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781669