2019 (12) TMI 218

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....HONOURABLE MS. JUSTICE SANGEETA K. VISHEN For the Petitioner : DARSHAN R PATEL(8486) For the Respondent : None ORAL ORDER (PER : HONOURABLE MS.JUSTICE HARSHA DEVANI) 1. Mr. Darshan Patel, learned advocate for the petitioner invited the attention of the court to the satisfaction note recorded by the Assessing Officer for issuing the impugned notices for assessment years 2012-13 to 20....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....document having been seized or requisitioned, there is no question of the same pertaining to or any information contained therein relating to the petitioner. It was submitted that from the satisfaction note it is evident that the gold has been sent to the petitioner for job work. It was submitted that the expression "job work" has not been defined in the Income Tax Act but has been defined under s....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....It was submitted that, therefore, if the gold seized is incriminating material against the petitioner, the same relates to assessment year 2018-19 in respect of which proceedings of scrutiny assessment have already been initiated. It was submitted that, therefore also, the impugned notices under section 153C are not sustainable. 3. Having regard to the submissions advanced by the learned advoca....