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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar U.S., Judicial Member, Renu Jauhri, Accountant Member
Rakesh Trisal – Appellant
Versus
DCIT Block-C-2 – Respondent
| Table of Content |
|---|
| 1. brief facts of search assessments under 153c. (Para 2 , 3) |
| 2. arguments on validity of consolidated satisfaction note. (Para 4 , 5 , 6) |
| 3. analysis of consolidated satisfaction note invalidity. (Para 7) |
| 4. quashing assessments for lack of year-wise satisfaction. (Para 8) |
| 5. appeals allowed; assessments quashed. (Para 9 , 10) |
ORDER
PER YOGESH KUMAR, U.S. JM:
The captioned appeals are filed by the Assessee against the orders of Ld. Commissioner of Income Tax (Appeals)-Delhi, 29 (‘Ld. CIT(A)’ for short), dated 10/07/2025 pertaining to Assessment Years 2016-17 and 2019-20 respectively.
2. Brief facts of the case are that, assessment orders came to be passed for Assessment Years 2016-17 and 2019-20u/s 153C r.w.s. 143(3) of the Income Tax Act, 1961 ('Act' for short)orders dated 30/03/2023 by making certain additions. The Assessee preferred two Appeals before the Ld. CIT(A). The Ld. CIT(A) vide orders dated 10/07/2025, dismissed the Appeals filed by the Assessee. As against the orders of the Ld. CIT(A), the Assessee preferred the captioned Appeals.
3. As the Appeals are filed by single Assessee, the captioned Appeals are heard together and decided in this common order.
4. Though
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