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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Raj Kumar Chauhan, Judicial Member, Manish Agarwal, Accountant Member
Phase-I, Gurgaon, Haryana-122017 – Appellant
Versus
Sudesh Gahlot, DCIT – Respondent
| Table of Content |
|---|
| 1. search initiated u/s 153c with bogus commission addition. (Para 2 , 3) |
| 2. assessee challenges common satisfaction note lacking year-wise segregation. (Para 4 , 5) |
| 3. department defends; assessee cites coordinate bench favoring invalidity. (Para 6 , 7) |
| 4. consolidated satisfaction note invalid without year-specific identification. (Para 8 , 9 , 10) |
| 5. assessment u/s 153c quashed for lack of valid jurisdiction. (Para 11 , 12) |
ORDER
PER MANISH AGARWAL, AM:
This appeal is filed by the Assessee against the order of the Ld. Commissioner of Income Tax (Appeals), Delhi-23 [‘ld. CIT(A)’ in short], dated 28.06.2025 in Appeal No. CIT(A)/Delhi-23/10927/2015-16 arising out of the assessment order passed u/s 153C of the Act, 1961 (the Act’ in short) dated 18.03.2023 for Assessment Year 2016-17.
2. Brief facts of the case are that assessee is an individual and furnished his return of income on 30.03.2017 declaring total income at Rs. 45,30,940/-. A search and seizure action u/s 132 was conducted in the case of M/s CIFSL, M/s BIDPL, Shri Harish Gahlot group of cases on 10.10.2018. Based on the material found during the course of search, the AO of the person searched had recorded the sat
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