M/s. Atoll Vyapaar (P) Ltd Vs DCIT

ITAT Delhi Quashes 153C Assessments Over Lack of ‘Bearing’ in Satisfaction Note The ITAT held that a valid Section 153C satisfaction note must clearly establish a direct link between seized material and the determination of taxable income. Since the AO failed to demonstrate this “bearing”, in conclusion, the tribunal quashed all assessments. The Income Tax…