Assessment under s.153C r.w.s.153A held invalid where AO adopted consolidated satisfaction and relied on extraneous material
X X X X Extracts X X X X
X X X X Extracts X X X X
....ITAT held that the assessment framed u/s 153C r.w.s. 153A was invalid. The AO of the searched person had factually misattributed seized mobile content to the assessee and forwarded a consolidated satisfaction note covering multiple AYs; the AO of the assessee impermissibly adopted that flawed note and relied on extraneous material (appraisal report, portal data, third-party statements) instead of forming an independent year-wise satisfaction confined to the seized material. Following precedent from Karn. HC, a consolidated satisfaction vitiates jurisdiction. Consequentially the assumption of jurisdiction and assessments under s.153C are void ab initio.....




TaxTMI
TaxTMI