https://www.taxtmi.com/caselaws?id=465600 Assessment under s.153C was held invalid because the AO failed to comply with mandatory preconditions. A satisfaction note is a sine qua non for invoking s.153C and must be recorded even where the AO of the searched person and the "other person" is the same officer; absent such recorded satisfaction, assumption of jurisdiction is vitiated. Further, s.153C can be triggered only on the basis of seized incriminating material that pertains to the assessment years sought to be reopened; where the seized material does not relate to the relevant years, proceedings cannot be sustained. Consequently, the s.153C assessment was quashed and relief granted to the assessee. en-us Wed, 21 Aug 2024 00:00:00 +0530 Fri, 02 Jan 2026 07:07:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465600 Assessment under s.153C was held invalid because the AO failed to comply with mandatory preconditions. A satisfaction note is a sine qua non for invoking s.153C and must be recorded even where the AO of the searched person and the "other person" is the same officer; absent such recorded satisfaction, assumption of jurisdiction is vitiated. Further, s.153C can be triggered only on the basis of seized incriminating material that pertains to the assessment years sought to be reopened; where the seized material does not relate to the relevant years, proceedings cannot be sustained. Consequently, the s.153C assessment was quashed and relief granted to the assessee. Case-Laws Income Tax Wed, 21 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465600