2026 (5) TMI 1862

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....ER For the Assessee : Shri Akhilesh Kumar, Adv. Shri Vipin Garg, CA Shri Ashok Saxena, CA For the Department : Ms. Amisha S Gupt, CIT DR ORDER PER SATBEER SINGH GODARA, JM: These assessee/appellant's five appeals ITA Nos. 7952 to 7956/Del/2025; for assessment years 2015-16 to 2019-20, arise against the Commissioner of Income Tax (Appeal)-3 [in short, "CIT(A)"], Noida's DINs & Order ....

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....f the said searched party recorded his former round of satisfaction nowhere making it clear as to whether the corresponding seized/ incriminating material in the nature of various documents in fact belonged or pertained or related to the assessee. We further emphasize here that the assessee's learned Assessing Officer thereafter recorded his latter round of satisfaction on 23.08.2023 in his case w....

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....ondition in recording of section 153C satisfaction at the learned Assessing Officer's behest is indeed fatal to the validity of assessment itself going by the stricter interpretation as per Commissioner vs Dilip Kumar and Company (2018) 9 SCC 1(SC) (FB). We accordingly reject the Revenue's vehement contentions supporting the impugned section 153C assessment and quash all these five assessments fra....