Assessment Invalid: Section 153C Lacks Proper Satisfaction Note, No Mention of Seized Material or Undisclosed Income.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Validity of Assessment u/s 153C - whether AO of the searched person has not recorded satisfaction note that the books of accounts/material belongs to the assessee ? - In the present case satisfaction note recorded by the AO there was no mention that he was satisfied about the undisclosed income belonging to the assessee on the basis of seized material - Merely on the basis of the order sheet entry, the assessment of present assessee has been reopened so as to frame the assessment u/s. 143(3) r.w.s. 153C - Being so, the requirement of section 153C of the Act has not been fulfilled. - AT....