Satisfaction Note by the AO for S.153C Assessment Need to Be Recorded for Each AY: ITAT Quashes ₹2.11 Crore Addition Citing Combined Satisfaction Note

The ITAT has quashed a "₹2.11 crore addition" to income, citing that a "combined satisfaction note" was invalid for a Section 153C assessment. The tribunal ruled that for such assessments, the satisfaction note must be recorded for "each assessment year" individually. The failure of the tax authorities to do so demonstrates a lack of proper application of mind and procedural irregularity, leading the tribunal to conclude that the assessment was invalid and without proper jurisdiction.