2024 (10) TMI 1160 - SCH - Income Tax

Validity of proceedings u/s 153C - whether the assessee should be treated as a Searched Person or Other Person ? - Whether Loose Sheets and Diary have any evidentiary value? - As decided by HC 2024 (2) TMI 116 - KARNATAKA HIGH COURT impugned notices issued u/s 153C based on the loose sheets/diaries are contrary to law, which require to be set aside in these writ appeals, as the same are void and illegal. As satisfaction note is required to be recorded under Section 153C of the IT Act for each Assessment Year and in the impugned proceedings, a consolidated satisfaction note has been recorded for different Assessment Years, which also vitiates the entire assessment proceedings. In view of all these findings, it is said that the appeals do not have any substance for seeking intervention as sought for by the appellant / Revenue. HELD THAT - Delay condoned. Heard the learned counsel appearing for the petitioners. We are not inclined to interfere with the impugned judgment passed by the High Court. Hence, the Special Leave Petitions are dismissed.

Summary

The Supreme Court dismissed the Special Leave Petitions after hearing counsel and declining to interfere with the impugned judgment passed by the High Court. Delay was condoned, and pending applications were disposed of.