Asset-based escaped-income satisfaction is mandatory for extended Section 153C jurisdiction; a cash-transaction note alone invalidates the assessment.
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....Section 153C jurisdiction for assessment years beyond the six preceding years requires the Assessing Officer to record satisfaction that escaped income is represented by an asset. The six-year period is reckoned from the assessment year relevant to the previous year in which seized material is received by the Assessing Officer having jurisdiction over the other person; on that basis, AY 2015-16 fell within the extended period. However, a satisfaction note referring only to alleged cash transactions did not establish the mandatory asset-representation condition. The assessment was therefore treated as void for lack of valid jurisdiction, and the consequential addition could not survive; issues concerning digital evidence, consolidated satisfaction and merits remained open.....
TaxTMI