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TMI Blog2024 (11) TMI 819X X X X Extracts X X X X X X X X Extracts X X X X ..... t assessment year covers AYs 2010-11 to 2015-16. In the case of the assessee, notice u/s 153C was issued to the assessee covering AY 2009-10 which is beyond jurisdiction as per the judicial precedence as held in the case of CIT-14 vs. Shree Jasjit Singh [ 2015 (8) TMI 982 - DELHI HIGH COURT] We note that AY 2009-10 which was covered by the AO u/s 153C is beyond jurisdiction. Accordingly, we set aside the assessment made in this case. Assessee appeal allowed. - Shri S. Rifaur Rahman, Accountant Member And Shri Sudhir Pareek, Judicial Member For the Assessee : Shri Ved Jain, Advocate, Shri Aman Garg, CA For the Revenue : Shri Sumer Singh Meena, CIT DR ORDER PER S.RIFAUR RAHMAN,AM: 1. This appeal is filed by the assessee against the order of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITAT Delhi in the case of DCIT, Central Circle 20, New Delhi vs. Rajesh Vashisht 2023 (12) TMI 294 dated 29.11.2023; (iv) ITAT Delhi in the case of M/s. Esha Securities Pvt. Ltd. vs. DCIT, Central Circle 13, New Delhi. (v) Jasjit Singh vs. ACIT, CC-11, New Delhi 2014 (11) TMI 1012 dated 05.11.2014; (vi) CIT-14 vs. Shree Jasjit Singh 2015 (8) TMI 982 dated 11.08.2015; (vii) CIT-7 vs. RRJ Securities Ltd. vice versa (2017 (4) TMI 1194 dated 25.04.2017; (viii) ARN Infrastructure India Ltd. vs. CIT, CC-28, New Delhi 2017 (8) TMI 733 dated 17.08.2017; (ix) DCIT, CC-14, New Delhi vs. M/s. Rajesh Sharma 2023 (8) TMI 1181 dated 23.08.2023; (x) ACIT, CC-13, New Delhi vs. Pragun Finance Pvt. Ltd. 2024 (7) TMI 1414 dated 30.05.2024; and (xi) M/s. KSJ I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 153C of the Act. Para 2.5 of the said circular clarifies as under :- The AO of the other person assumes jurisdiction under Section 153C with the receipt of the relevant seized material from the AO of the searched person. Also, a copy of the satisfaction received from the AO of the searched person in this regard would enable him to proceed further in the case of the other person under Section 153C. Though there is no statutory requirement for the AO of such other person to record any satisfaction/reason before issuing notice under Section 153C and proceeding further, considering the above aspects. It is advisable for maintaining institutional memory that the AO records receipt of the seized material and the satisfaction from the AO o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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