153C Assessment Quashed for Want of Year Specific Satisfaction Note

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has upheld the order of the CIT(A) quashing proceedings initiated under Section 153C of the Income-tax Act, 1961, holding that a consolidated satisfaction note covering multiple assessment years without identifying year-specific incriminating material is legally unsustainable. 

The Tribunal reiterated that the existence of incriminating material relatable to each assessment year and a specific satisfaction recorded by the Assessing Officer are jurisdictional prerequisites for invoking Section 153C.