Case Law Analysis
|Income Tax Appellate Tribunal
Section 153C IT Act | Seized Material Must Be Correlated to Specific Assessment Year to Validate Assessment: ITAT Delhi
ITAT Delhi rules that assessments under Section 153C of the Income Tax Act are void ab initio if seized materials are not explicitly linked to a specific assessment year. The Tribunal relied on the Bombay HC precedent in CIT Vs. Sinhgad Technical Education Society, affirming that jurisdictional defects cannot be cured by generic satisfaction notes. This ruling reinforces strict compliance requirements for search-and-seizure proceedings, impacting tax authorities and assessees alike.