https://www.taxtmi.com/caselaws?id=783560 The dominant issue was whether proceedings under s.153C were validly initiated based on the AO's recorded satisfaction. The ITAT held that a valid satisfaction must state not only that the seized material "belongs to" the assessee, but also that it has a bearing on determination of the assessee's income. Here, the satisfaction note was internally inconsistent (stating the entries belonged to the assessee yet did not pertain to the assessee) and omitted the statutory requirement that the material impacted income determination; applying the HC ruling in Saksham Commodities, the satisfaction was held invalid. Consequently, the s.153C proceedings and the consequent order passed under s.153 were quashed, and the assessee's ground was allowed. en-us Fri, 12 Dec 2025 00:00:00 +0530 Thu, 18 Dec 2025 08:01:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783560 The dominant issue was whether proceedings under s.153C were validly initiated based on the AO's recorded satisfaction. The ITAT held that a valid satisfaction must state not only that the seized material "belongs to" the assessee, but also that it has a bearing on determination of the assessee's income. Here, the satisfaction note was internally inconsistent (stating the entries belonged to the assessee yet did not pertain to the assessee) and omitted the statutory requirement that the material impacted income determination; applying the HC ruling in Saksham Commodities, the satisfaction was held invalid. Consequently, the s.153C proceedings and the consequent order passed under s.153 were quashed, and the assessee's ground was allowed. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783560