Jurisdictional Satisfaction Under Section 153C Requires Substantive Reasoning, Not Mere Perfunctory Recording of Search Details

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....ITAT held that jurisdictional assumption under Section 153C requires a substantive and descriptive satisfaction note. Mere perfunctory recording without tangible information and proper application of mind cannot confer assessment jurisdiction. The cryptic satisfaction note lacking specificity of searched documents/assets against respective assessment years renders the entire proceeding legally unsustainable. Consequently, the notice and consequent assessment order issued under Section 153C stand quashed, with the assessee's appeal being allowed.....