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    <title>2025 (9) TMI 1769 - ITAT PUNE</title>
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    <description>Section 153C jurisdiction was examined on the basis of a common satisfaction note covering assessment years 2012-13 to 2018-19. The Tribunal&#039;s view was that satisfaction must be recorded year-wise for the relevant assessment year, and that a consolidated note for multiple years vitiates the assumption of jurisdiction. Because the jurisdictional challenge went to the root of the proceedings, the additions were treated as academic. On that basis, the combined satisfaction note was said to invalidate the section 153C proceedings and the assessment was quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=467607</link>
      <description>Section 153C jurisdiction was examined on the basis of a common satisfaction note covering assessment years 2012-13 to 2018-19. The Tribunal&#039;s view was that satisfaction must be recorded year-wise for the relevant assessment year, and that a consolidated note for multiple years vitiates the assumption of jurisdiction. Because the jurisdictional challenge went to the root of the proceedings, the additions were treated as academic. On that basis, the combined satisfaction note was said to invalidate the section 153C proceedings and the assessment was quashed.</description>
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