AO's Failure to Record Satisfaction u/s 153C Invalidates Jurisdiction Over Seized Documents Impacting Income.

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....The assessment u/s 153C mandates the recording of satisfaction by the Assessing Officer (AO) upon discovery of material likely to "have a bearing on the determination of the total income." Proceedings u/s 153C can be initiated only upon the AO's satisfaction of the other person on receipt of the seized material from the AO of the searched person. The AO shall then proceed against such other person, issue notice, and assess or reassess the income in accordance with Section 153A, if satisfied that the seized books of account, documents, or assets have a bearing on the determination of the total income for six assessment years immediately preceding the search/requisition year. However, the AO failed to record how the seized documents have a be.........