Assessment Proceedings Void Due to Missing Satisfaction Note by AO; Sections 153C/263/143(3) Invalidated.

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....Assessment framed u/s. 153C/263/143(3) - Such satisfaction note along with seized material is passed over to the ld. AO of ‘other person’. Thereafter, the ld.AO of the ‘other person’ is again required to prepare the ‘satisfaction note’ stating that such seized material belongs to ‘other person’, who is under his jurisdiction. In the instant case before initiation of proceeding u/s. 153C of the Act the ld. AO has not prepared the satisfaction note. - proceeding u/s. 153C r.w.s 143(3) are void and ab initio. - AT....