Satisfaction Note Requirement under section 153C: assessment lacked jurisdiction and was time barred when limitation fixed at handing over.

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....Recording of a satisfaction note by the assessing officer of the searched person is a jurisdictional prerequisite to initiate proceedings and frame assessment in respect of a non-searched person under section 153C; absence of that satisfaction note vitiates jurisdiction and merits quashing of the assessment. Where limitation for an assessment year is to be computed, the relevant date is the date of satisfaction/handing over of records; applying that date, the Tribunal found the assessment year barred by limitation and quashed the assessment. The Tribunal therefore dismissed the Revenue's appeal and upheld quashing of the assessment.....