Income Tax Assessments Under Section 153C Quashed Due to Invalid Satisfaction Note and Jurisdictional Time Limits

ITAT invalidated assessments under s.153C read with s.153A for AYs 2011-12 and 2012-13. The AO recorded satisfaction note on 25.09.2018, making AY 2019-20 the relevant search assessment year. The years under dispute fell outside jurisdictional scope of revision proceedings. The satisfaction note for block period AYs 2011-12 to 2017-18 failed to establish document-wise correlation with assessment years in question, lacking essential elements required under s.153C. The Tribunal quashed assessment orders made under s.153A(1)(b) and allowed assessee's appeal, finding fundamental jurisdictional defect in proceedings initiated based on inadequate satisfaction note. .....

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