2018 (2) TMI 1381 - SCH - Income Tax

Assessment u/s 153C - existence of satisfaction note - Held that - Special Leave Petitions are dismissed. HC order confirmed. 2017 (7) TMI 539 - DELHI HIGH COURT HC has held that while the documents may pertain to the Assessee, but in the context explained above, they cannot be presumed to be documents that belonged to the searched person. Consequently, even with regard to these documents, the jurisdictional requirement under Section 153 C (1) of the Act, of the AO of the searched person having to be satisfied that the said documents do not belong to searched person but to the Assessee, has not been fulfilled. The satisfaction note prepared by the AO of the searched person does not fulfill the legal requirement spelled out in Section 153C (1) of the Act. The satisfaction note of the AO of the Assessee, being a carbon copy of the satisfaction note of the AO of the searched person also fails to fulfill the jurisdictional requirement. - Decided in favour of assessee