Reassessment under s.153C invalidated; s.69 additions deleted due to omnibus satisfaction and uncorroborated pen drive evidence

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....ITAT allowed the appeal, holding the reassessment proceedings under s.153C invalid and the additions under s.69 deleted. The Tribunal found the AO's satisfaction note to be a consolidated, non-year-specific record, failing the statutory requirement of distinct, contemporaneous satisfaction relatable to each assessment year; such omnibus satisfaction vitiates jurisdiction and renders proceedings void ab initio. Further, the alleged incriminating material-a pen drive seized from a third party-was held to be a "dumb document": not seized from the assessee, not authenticated by the custodian, lacking year-wise nexus, corroborative bank or asset evidence, and denied by the assessee. In absence of independent corroboration, the additions were arbitrary and unsustainable.....