https://www.taxtmi.com/caselaws?id=782988 ITAT Delhi-AT allowed the assessee's appeal by holding that the initiation of proceedings under s.153C was invalid. The AO of the assessee had not recorded an independent, cogent satisfaction based on application of mind to the material received from the AO of the searched person, but had merely reproduced the latter's satisfaction note. Relying on binding HC precedent, the Tribunal held that such "carbon copy" satisfaction does not meet the statutory requirement under s.153C. Consequently, the initiation of proceedings under s.153C and the resultant assessment order were held to be bad in law and were quashed, thereby allowing the assessee's legal grounds. en-us Thu, 27 Nov 2025 00:00:00 +0530 Mon, 08 Dec 2025 08:31:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782988 ITAT Delhi-AT allowed the assessee's appeal by holding that the initiation of proceedings under s.153C was invalid. The AO of the assessee had not recorded an independent, cogent satisfaction based on application of mind to the material received from the AO of the searched person, but had merely reproduced the latter's satisfaction note. Relying on binding HC precedent, the Tribunal held that such "carbon copy" satisfaction does not meet the statutory requirement under s.153C. Consequently, the initiation of proceedings under s.153C and the resultant assessment order were held to be bad in law and were quashed, thereby allowing the assessee's legal grounds. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782988