ITAT quashed Assessment – Illegal assumption of jurisdiction as satisfaction note recorded in a mechanical manner, without due application of mind




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ITAT quashed Assessment – Illegal assumption of jurisdiction as satisfaction note recorded in a mechanical manner, without due application of mind

 

Hon’ble Delhi Tribunal in the case of Rajiv Agarwal v. ACIT, Central Circle Delhi-20, dated 04.12.2024,

The Hon’ble Tribunal quashed the proceedings under Section 153C of the Income Tax Act, 1961, on account of being based on illegal assumption of jurisdiction, as the satisfaction note in the case of the assessee was recorded in a mechanical manner, without due application of mind since it was almost identically worded to the satisfaction note recorded by the Assessing Officer of the searched person and also the reasons mentioned therein do not demonstrate how the nature of seized material has bearing on the total income of the assessee, and to which assessment year particularly. In other words, the satisfaction note failed to reflect any rational connection with or relevant bearing on the alleged seized material and the alleged undisclosed income of the assessee for a particular year sought to be assessed u/s 153C.

The Copy of the order is as under:

1735647829-qDvyK3-1-TO




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