2017 (12) TMI 588 - SCH - Income Tax

Validity of Notice u/s 153C - issuance of a notice by an AO of a person who has not been searched, on the basis of a satisfaction note prepared by the AO of a searched person - satisfaction Held that - SLP dismissed. HC order confirmed 2014 (8) TMI 425 - DELHI HIGH COURT . Mere use or mention of the word satisfaction or the words I am satisfied in the order or the note would not meet the requirement of the concept of satisfaction as used in Section 153C of the Act - The satisfaction note itself must display the reasons or basis for the conclusion that the AO of the searched person is satisfied that the seized documents belong to a person other than the searched person thus, the very first step prior to the issuance of a notice u/s 153C has not been fulfilled the condition precedent has not been met, the notices u/s 153C are liable to be quashed Decided in favour of Assessee.