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    <title>2026 (2) TMI 1377 - ITAT DELHI</title>
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    <description>Action under Section 153C requires a jurisdictional assessing officer to record year-specific satisfaction identifying which assessment year(s) received material relates to and explaining how that material is likely to affect determination of income for those years; a consolidated satisfaction note lacking year-wise identification or reasons is invalid. Applying this principle, the consolidated satisfaction recorded here did not specify incriminating material year-wise or reason how it would impact particular years, so the assumption of jurisdiction under Section 153C was vitiated, the assessments framed thereunder were quashed, and the consequential penalty dependent on those assessments was also quashed.</description>
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    <pubDate>Thu, 26 Feb 2026 00:00:00 +0530</pubDate>
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      <title>2026 (2) TMI 1377 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=787229</link>
      <description>Action under Section 153C requires a jurisdictional assessing officer to record year-specific satisfaction identifying which assessment year(s) received material relates to and explaining how that material is likely to affect determination of income for those years; a consolidated satisfaction note lacking year-wise identification or reasons is invalid. Applying this principle, the consolidated satisfaction recorded here did not specify incriminating material year-wise or reason how it would impact particular years, so the assumption of jurisdiction under Section 153C was vitiated, the assessments framed thereunder were quashed, and the consequential penalty dependent on those assessments was also quashed.</description>
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      <pubDate>Thu, 26 Feb 2026 00:00:00 +0530</pubDate>
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