Section 153C Assessment Requires AO Satisfaction Note; Documents Must Link to Appellant from Searched Premises.

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....Assessment u/s 153C - recording of satisfaction - A perusal of the satisfaction note would indicate that the AO nowhere held that documents belonged to the present appellants were found at the premises of searched person/entity. Though, section 153C is a procedural section, but the jurisdiction to assess an assessee under this section is being invoked with help of the section. - AT....