2021 (5) TMI 101

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.... 2. In these cases, the assessment order framed u/s. 143(3) r.w.s. 153C of the Income Tax Act, 1961 ('the Act') consequent to search in the case of RNS Infrastructure Limited and others on 16.02.2012. The assesses in all these appeals, inter alia, raised the legal ground with regard to non-recording of satisfaction by the Assessing Officer of searched persons. 3. The learned Authorised Representative submitted that the assesses sought for copies of order sheet entry to know the satisfaction recorded by the Assessing Officer of searched persons so as to issue Notice by the Assessing Officer to the assessee u/s. 153C of the Act. However, the Assessing Officer refused to supply the satisfaction recorded to invoke the provisions of ....

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....e assesses. Thereafter, the Assessing Officer of these assesses issued Notices u/s. 153C of the Act. According to the ld. DR, since the assesses have not raised the issue regarding recording of satisfaction before the respective Assessing Officer at the time of assessment, he cannot raise the same before the CIT (Appeals) or before the Tribunal. He relied on the orders of CIT (Appeals). 5. We have heard both the parties and perused the material on record. As per Section 153C of the Act, the Assessing Officer of searched person shall proceed against such other person on reaching satisfaction that any undisclosed income belonging to such other person over whom he has no jurisdiction then he has to transmit the seized material to the Assess....