recorded the
satisfaction note in the file of the assessee-company which
is reproduced as under:
"Satisfaction u/s 153C of the Income ... reading the above satisfaction
note found that the Assessing Officer of the assessee-
company recorded the satisfaction note under section 153C
person
and there is no satisfaction or even the basis for
satisfaction to issue a notice u/s. 153C and no
satisfaction is recorded ... person and there is no satisfaction or even the basis for
satisfaction to issue a notice u/s 153C and no satisfaction is
recorded
Assessing Officer in both these two assessment years
recorded section 153C satisfactions. The same is dated 14-07-2011
in Shri Darji's cases ... above stated
decision requiring an Assessing Officer to record section 153C
satisfaction first in case of the searched assessee followed by a
similar exercise
number of Paper Book-01. The satisfaction note reads as below:-
"Satisfaction note for proceedings u/s 153C of the Income ... satisfaction under
section 153C , except the words satisfaction in the heading
satisfaction note for proceedings under section 153C , at no
other place word satisfaction
recorded the satisfaction note in the file of the
assessee-company which is reproduced as under:
"Satisfaction u/s 153C of the Income ... reading the above satisfaction
note found that the Assessing Officer of the assessee-
company recorded the satisfaction note under section
153C
number of Paper Book-01. The satisfaction note reads as below:-
"Satisfaction note for proceedings u/s 153C of the Income ... satisfaction under
section 153C , except the words satisfaction in the heading
satisfaction note for proceedings under section 153C , at no
other place word satisfaction
Delhi High Court held that in view of
provisions of section 153C , satisfaction that is
required to be reached by Assessing Officer having
jurisdiction over ... contents of the satisfaction note, we are unable to discern any
"satisfaction" of the kind required under Section 153C of the said
Assessing Officer of the searched person (as mentioned in Section
153C). The satisfaction note states "notices u/s 153C are hereby
issued ... communication of satisfaction.
"7. As per amended provisions of s. 153C, satisfaction has to be arrived
at with regard to belongingness of a document
recording of any satisfaction in the appraisal note by the
ADI, will not amount to proper satisfaction as stipulated u/s
153C for assuming jurisdiction ... 153C . The assumption of
jurisdiction and framing of assessment by the
Assessing Officer u/s 153C without recording such
satisfaction is void ab initio. Applying
ground that satisfaction under section 153C of
the Act was not recorded by the Assessing Officer of the searched
person. The assessment for the Assessment ... under section 153C
of the Act or immediately after the assessment
proceedings are completed under section 153C of the Act,
recording of satisfaction is required
