ITAT quashed sec. 153C block proceedings as AO didn't record satisfaction that seized docs belonged to other person

IT : Where Assessing Officer of 'B', 'P' and 'MB' did not record any satisfaction that some money, bullion, jewellery or books of account or other documents found from these persons belonged to assessee, initiation of proceedings under section 153C on assessee was void ab initio

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[2015] 54 taxmann.com 379 (Delhi - Trib.)

IN THE ITAT DELHI BENCH 'H'

Tanvir Collections (P.) Ltd.

v.

Assistant Commissioner of Income Tax, Central Circle-21, New Delhi

Section 153C, read with sections 153A and 132, of the Income-tax Act, 1961 - Search and seizure - Assessment of income of any other person (Recording of satisfaction) - Assessment year 2003-04 - Whether where Assessing Officer of 'B', 'P' and 'MB' did not record any satisfaction that some money, bullion, jewellery or books of account or other documents found from these persons belonged to assessee, initiation of proceedings under section 153C on assessee was void ab initio - Held, yes [Para 26] [In favour of assessee]