2019 (9) TMI 779

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....e case of the assessees from DCIT, Sangrur to DCIT, Karnal. Admitted facts of the case are that the assessees started their operation in the year 2005-2006. In the year 2013-14, three Directors of M/s Jai Bharat Group were inducted as Directors of the petitioners' company (after acquiring adequate share holding). On 3.5.2018 a search and seizure was conducted at the residential premises of the M/s Jai Bharat Group and a lot of incriminating material was found there. Thereafter, a survey was conducted in the business premises of the assessees' group but nothing incriminating was found. Subsequently, a notice was issued to the petitioners' company on 27.6.2018. The operative part of which is as follows :- "In this regard, it ....

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....it for comments which were sent on 14.12.2018 Annexure R-2 and it was pointed out that during the course of search proceedings at the premises of M/s. Jai Bharat Group, some incriminating documents related to both the assessees were found and impound. It was further mentioned that the data of a computer installed at the premises also contained reference to bogus billing which had been indulged by both these groups. After receipt of this letter, ultimately, the impugned order dated 2.1.2019 Annexure P-6 was passed. A perusal of this order also states that there is no reason indicated therein, and rather the order proceeds on the basis of that both are 'related concerns'. Learned Senior counsel for the petitioners has argued that no....