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1. The assessment u/s 153C mandates the recording of satisfaction by the Assessing Officer (AO) upon discovery of material likely to "have a bearing on the determination of...

2. Absence of valid satisfaction recorded by AO before initiating assessment under special provision where search took place. Satisfaction note did not reveal AO's averment...

3. The ITAT held that for penalty u/s 271D for contravention of section 269SS, recording satisfaction by AO is mandatory. Citing Jaya Laxmi Rice Mills case, it emphasized...

4. The Appellate Tribunal (ITAT) considered the validity of proceedings u/s 153C, focusing on whether the satisfaction note recorded by the AO of the searched person was...

5. Penalty u/s 271(1)(c) - recording of satisfaction - penalty initiated u/s 143(3) order for concealment of particulars of income - penalty imposed for furnishing of...

6. Penalty u/s 271(1)(c) - recording of satisfaction - mere direction in the assessment order to initiate penalty proceedings - Concealment/furnishing inaccurate...

7. Assessment u/s 153A/153C - recording of satisfaction as the AO of the searched person is mandatory to initiate the proceedings even if AO for both the same and...

8. Revision u/s 263 - AO did not initiate penalty proceedings u/s. 271(1) (c) - No hesitation in holding that the CIT is not correct in assuming jurisdiction u/s 263 of the...

9. Reopening of assessment u/s 147 - The entire exercise of re-opening would depend upon the reasons recorded by the AO and therefore the reasons recorded to re-open the...

10. Concealment of turnover - validity of assessment and Levy of penalty - recording of satisfaction is sine qua non before proceeding to impose tax and penalty upon the...

11. Disallowance u/s 14A r.w.r. 8D - no proper recording of satisfaction by the AO for rejecting the suomoto disallowance made by the Assessee - The Tribunal found that in...

12. Validity of Assessment u/s 153C - whether AO of the searched person has not recorded satisfaction note that the books of accounts/material belongs to the assessee ? - In...

13. AO did not record his satisfaction for initiation of penalty proceedings, because while passing the assessment order passed u/s. 143(3)(ii), the AO has stated that “….....

14. Assessment u/s 153C - satisfaction on the basis of the borrowed information - It is true that the supreme Court has made the said observations while considering the...

15. Validity of assessment u/s 158BC r.w.s. 158D - The satisfaction recorded by the AO as per Revenue is incorporated in the order sheet and not in the notice. Thus, it is...