setting in motion an assessment under Section 153C is
recording satisfaction under Section 153C of the Act. The assessee
and the searched person are different ... contents of the satisfaction note, we are
unable to discern any "satisfaction" of the kind required
under section 153C of the said
153A and that of AO for issuing
notice u/s 153C is as under :
(Satisfaction of AO of person referred to in section 153A ... relied on the above material only for recording
satisfaction for initiating proceedings u/s.153C , it can not be said
that the satisfaction is based
from the above judgment that the
satisfaction recorded is no satisfaction at all to initiate proceedings
u/s 153C of the Act. The term ... Satisfaction u/s 1588D rendered in the case of Calcutta
Knitwear case be accepted as applicable to the satisfaction u/s
153C
concluded and was not pending on the date of recording satisfaction
under section 153C, therefore the assessment order passed under
section 153C ... after examining the assessment records held
that no satisfaction u/s 153C has been recorded by the A.O. of the searched
person
satisfaction recorded. Since no additions have been made qua
the item for which satisfaction was recorded by the Assessing
Officer under Section 153C ... seized. After recording
satisfaction vide satisfaction note, dated 03.10.2017, the
Assessing Officer proceeded to issue notice under Section 153C
of the Act to the Assessee
away by provision of section 153C , as addition u/s.153C will be
restricted to incriminating documents mentioned in satisfaction
Note as propounded ... 153C of the Act only after
issuing u/s. 153C of the Act. Therefore, since admittedly no
notice u/s. 153C
notice
u/s.153C has duly covered all the important aspects to
assess the assessee u/s.153C while preparing satisfaction
note.
ITA No. 1890 ... contents of the satisfaction note, we are unable
to discern any "satisfaction" of the kind required under Section
153C of the said
pending on
the date of recording satisfaction under section 153C, therefore the
assessment order passed under section 153C ... recording satisfaction by the
A.O. of searched person. In the present case, admittedly the satisfaction
recorded by the A.O. u/s 153C
application moved by the
assessee for seeking the record of satisfaction u/s 153C of the
Act. It was submitted that the admission ... 153C and
completed the assessment u/s 153C. The appellant therefore, submit
that the assessment that is made u/s 153C is void ab initio
satisfaction of the Assessing Officer of the other person. He
submitted, in assessee's case, the satisfaction was recorded in
terms of section 153C ... case, it would be the date of
the recording of satisfaction under Section 153C of the Act,
i.e.. 8th September, 2010. In this view
