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K. R. SHRIRAM, FIRDOSH P. POONIWALLA
Ashok Commercial Enterprises – Appellant
Versus
Assistant Commissioner of Income Taxation – Respondent
JUDGMENT :
K.R. SHRIRAM, J.
1. Petitioner had filed nine Writ Petitions challenging notices dated 19th July 2021 and 14th July 2021 issued under Section 153 of the Income Tax Act, 1961 (the Act) for Assessment Year 2011-2012 (WP No.2501 of 2021), Assessment Year 2012-2013 (WP No.2432 of 2021), Assessment Year 2013-2014 (WP No.2411 of 2021), Assessment Year 2014- 2015 (WP No.2403 of 2021), Assessment Year 2015-2016 (WP No.2415 of 2021), Assessment Year 2016-2017 (WP No.2423 of 2021), Assessment Year 2017-2018 (WP No.2424 of 2021), Assessment Year 2018-2019 (WP No.2399 of 2021) and Assessment Year 2019-2020 (WP No.2395 of 2021). Subsequent to filing of these petitions, assessment orders were passed pursuant to the above mentioned notices for the Assessment Years 2011-2012 to 2019-2020. The said assessment orders were also challenged by filing nine separate Writ Petitions mentioned in the cause title for Assessment Years 2011-2012 to 2019-2020 and the grounds of challenge included those raised in the earlier nine petitions. For the reasons set out in the order of this Court passed o
Consolidated satisfaction note under section 153C without year-wise segregation of incriminating material for each assessment year is invalid, quashing jurisdiction and assessment proceedings.
Consolidated satisfaction note u/s 153C for multiple years without year-specific incriminating material is invalid and quashes assessment jurisdiction.
Consolidated satisfaction note under S.153C without year-specific incriminating material invalidates jurisdiction for assessments.
Consolidated satisfaction note u/s 153C without year-wise incriminating material is invalid and vitiates jurisdiction for assessment proceedings.
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