2025 (12) TMI 1517

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....ctively. As the appeals are pertaining to single assessee, involving similar issues to be decided, above appeals are heard tougher and decided in this common order. 2. Ld. Counsel for the assessee submitted that the AO who has passed the assessment orders u/s 153C of the Income Tax Act, 1961 ('Act' for short) has not recorded the satisfaction note. Since, the assessment has been framed by the concerned AO without recording the satisfaction, the assessment orders for the Assessment Years under consideration are liable to quashed. The Ld. Counsel has relied on the following judgments in support of his contentions. * Ratio of decision of Hon'ble Delhi High Court in the case of M/s Saksham Commodities Ltd. &Ors dated 09.04.2....

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....ilable in record. In the present case, the notice u/s 153C of the Act has been issued by DCIT, Central Circle-30 on 17.10.2022. It is evident from the record that the jurisdiction in the case of the assessee has been transferred u/s 127 of the Act by PCIT-12 on 05.09.2022 itself from DCIT, Circle-61(1) to DCIT, Central Circle-30 which can be corroborated from page 191-192 of the PB. The satisfaction has been recorded by an Officer namely Sh. Praduman Meena, DCIT, Central Circle-30, Delhi in the capacity of AO of the 'Searched person'. After recording the satisfaction, the DCIT, Central Circle-30, Delhi on 16.08.2022 handed over the seized material, satisfaction recorded and the punchanama to the jurisdictional AO of the assessee at that poi....