
Case Law Analysis
|Income Tax Appellate Tribunal
Section 153C satisfaction notes must be year-wise; notices issued beyond 15 months are time-barred | ITAT quashes assessment orders : ITAT Delhi
The Delhi ITAT set aside assessment orders for AY 2016-17 and 2017-18, ruling that a single omnibus satisfaction note under Sec 153C is invalid without year-wise linkage of seized material to income. It also declared that notices served after the statutory 15-month limitation are void. Taxpayers must ensure separate satisfaction notes for each year and timely notices.
