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S. 153C Assessments Invalid as AO’s Satisfaction Note Fails to Show Seized Material had “bearing on determination of total income”: ITAT

24/12/2025

The Delhi Bench ‘G’ of the Income Tax Appellate Tribunal (ITAT) has quashed assessments framed under Section 153C as invalid as AO’s satisfaction note fails to show seized material had “bearing on determination of total income”. The bench Satbeer Singh Godara (Judicial Member) and Manish Agarwal (Accountant Member) held that a clinching fact in the…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 5+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started as a freelance tax reporter in the leading online legal news companies like LiveLaw & Taxscan.

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S. 153C Assessments Invalid as AO’s Satisfaction Note Fails to Show Seized Material had “bearing on determination of total income”: ITAT

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S. 153C Assessments Invalid as AO’s Satisfaction Note Fails to Show Seized Material had “bearing on determination of total income”: ITAT

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