2025 (10) TMI 224

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....r the Department : Ms. Monika Singh, CIT (DR) ORDER PER AMITABH SHUKLA, A.M: This appeal, preferred by the Revenue for assessment year 2010-11, is directed against the order of Commissioner of Income-tax (Appeals)-XXVI, New Delhi dated17.09.2019 in appeal No. 10235/16-17 against the order dated 31.03.2016 passed by the ACIT, CC-13, New Delhi u/s 143(3)/153C of the Income-tax Act (hereinaf....

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....3. It has been submitted that in this case regular assessment u/s 143(3) was conducted on 08.03.2013 and that thereafter consequent to the search, proceedings action u/s 153C was initiated against the assessee. The Ld.Counsel for the assessee has argued that the Ld.CIT(A) in this case has rightly deleted the addition by holding that the order passed u/s 153C is not based upon correct satisfaction ....

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....eferred on said page number 17 of the impugned seized annexure. 5.0 We have noted that Ld.CIT(A) on pages 8 to 10 of his order extensively dealt this issue before concluding that as the satisfaction note u/s 153C is factually incorrect, the corresponding reassessment order would not survive. Pertinently, while arriving at the impugned conclusion, the Ld.First Appellate Authority has placed reli....