Section 153C: AO Must Clearly State Seized Documents Belong to Another for Tax Proceedings to Begin.

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....Validity of initiation of proceedings u/s 153C - validity of satisfaction note - it is the duty of the AO to apply his mind and should consciously and mandatorily state in the satisfaction note that the seized documents belong to “other person”. Without recording such a satisfaction, it cannot be presumed that the seized materials belong to “other persons”, in which case the AO could not have initiated proceedings against the “other persons” u/s 153C of the Act. - AT....