Tax Assessments Quashed for 2009-2012: Invalid Notices and Jurisdiction; Additions Unsustainable Due to Procedural Errors.

The ITAT held that the assessment years 2009-10, 2010-11 and 2011-12 were beyond the 10-year limitation period u/s 153C read with Explanation-1 to section 153A. Hence, the notice issued and assessments made u/s 153C for these years were barred by limitation, invalid, and quashed for want of valid jurisdiction. The consolidated satisfaction notes recorded by the AOs for multiple years were improper as separate notes were required year-wise. The additions made u/s 68 for the years 2009-10 to 2013-14 were unsustainable due to lack of jurisdiction and invalid, and hence quashed. The approval granted u/s 153D was treated as invalid and bad in law due to lack of proper application of mind and recording of satisfaction by the Addl. CIT. The additi..... .....

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