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Assessment under Section 153C set aside due to invalid satisfaction note and lack of jurisdiction over AY 2015-16 to 2021-22
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....The ITAT set aside the assessment framed u/s 153C due to the AO's failure to record a valid satisfaction note specifying escaped income for each assessment year, thereby invalidating jurisdiction. The AO's assumption of jurisdiction over A.Y. 2015-16 to 2021-22 was quashed as the satisfaction note was cryptic and did not demonstrate application of mind. The extended limitation period under section 153A was held inapplicable as the alleged escaped income was below Rs. 50 lakhs. The assessment related to A.Y. 2023-24 only, computed from the date incriminating material was received. The addition for alleged on-money payments was deleted for lack of evidence and denial of cross-examination. Enhancement under section 69 was also deleted as the s.........