
Case Law Analysis
|Income Tax Appellate Tribunal
Section 153C Income Tax Act | Assessments Time-Barred If Satisfaction Note Not Recorded Within 6 AYs: ITAT Delhi Upholds Ojjus Medicare Precedent
ITAT Delhi quashes assessments for AY 2014-15 and 2015-16, ruling that satisfaction notes under Section 153C must be recorded within six assessment years to validate proceedings. The tribunal reaffirms the Delhi High Court’s holding in Ojjus Medicare, emphasizing strict procedural compliance to prevent time-barred assessments.