<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2025 (12) TMI 1517 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=783977</link>
    <description>The dominant issue was whether assessments framed under s.153C were valid when the AO issuing the notice and framing the assessment did not record the requisite satisfaction note. The Tribunal held that although jurisdiction had been transferred under s.127 and a satisfaction was recorded by the AO of the searched person, the seized material and satisfaction were earlier handed over to a different jurisdictional AO of the other person, and the AO who ultimately framed the s.153C assessments did so without recording satisfaction as mandated by law; applying the HC ratio in Shaksham Commodity Ltd., the s.153C assessment orders were quashed.</description>
    <language>en-us</language>
    <pubDate>Tue, 23 Dec 2025 00:00:00 +0530</pubDate>
    <lastBuildDate>Fri, 26 Dec 2025 07:18:35 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=873981" rel="self" type="application/rss+xml"/>
    <item>
      <title>2025 (12) TMI 1517 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783977</link>
      <description>The dominant issue was whether assessments framed under s.153C were valid when the AO issuing the notice and framing the assessment did not record the requisite satisfaction note. The Tribunal held that although jurisdiction had been transferred under s.127 and a satisfaction was recorded by the AO of the searched person, the seized material and satisfaction were earlier handed over to a different jurisdictional AO of the other person, and the AO who ultimately framed the s.153C assessments did so without recording satisfaction as mandated by law; applying the HC ratio in Shaksham Commodity Ltd., the s.153C assessment orders were quashed.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Tue, 23 Dec 2025 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=783977</guid>
    </item>
  </channel>
</rss>