#Jurisdictional Validity

The ITAT Delhi has ruled that an assessment under Section 153C cannot stand unless incriminating material directly belonging to the assessee is discovered during a search of a third party. This clarifies a critical jurisdictional limit on the tax department’s power to reassess unrelated taxpayers, reinforcing natural justice and statutory compliance in income tax proceedings.

The ITAT Delhi has ruled that a single, consolidated satisfaction note covering multiple assessment years under Section 153C violates the statutory requirement for individualized judicial satisfaction per year, rendering the entire search-based assessment void. This sets a critical precedent for tax officers: each assessment year must have a distinct, independent satisfaction record to validate jurisdiction, impacting all pending and future search assessments.

ITAT Delhi holds that reassessment proceedings under Section 147/148 of the Income Tax Act are vitiated if the approval under Section 151 is granted mechanically without independent application of mind. The ruling mandates that authorities must record reasoned approval, impacting all pending and future reassessment cases.

ITAT Delhi rules that reassessment under Section 153C of the Income Tax Act is invalid if the satisfaction note is recorded after 01.04.2021, as only Section 148 proceedings are permissible thereafter. The ruling underscores strict compliance with jurisdictional timelines, impacting tax authorities' assessment powers.

ITAT Delhi rules that a consolidated satisfaction note under Section 153C IT Act for multiple assessment years is invalid, violating the Supreme Court's precedent in Sunil Kumar Sharma. The Tribunal quashed the assessment for AY 2017-18, reinforcing that jurisdictional validity hinges on year-specific satisfaction notes, impacting tax litigation and assessment proceedings.

ITAT Mumbai ruled that reassessment proceedings initiated beyond three years from the relevant assessment year are invalid if approved by an incorrect authority under Section 151(ii) of the Income Tax Act. The tribunal held that only the 'specified authority' as amended in 2021 could grant approval, rendering the notice and subsequent proceedings null and void. This decision reinforces jurisdictional compliance in tax reassessment cases, impacting taxpayers and revenue authorities alike.

Madhya Pradesh High Court rules that an arbitration award remains valid if the arbitrator was appointed before a subsequent jurisdictional ruling (L.G. Chaudhary). The decision protects finality of awards where procedural fairness was observed at the time of appointment, preventing retroactive invalidation.

Andhra Pradesh High Court rules that jurisdictional assessing officers lack authority to issue notices under Section 147 IT Act outside the faceless assessment mechanism prescribed under Section 144B read with Section 151A.