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2015 (10) TMI 2775

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....M APPL No. 22570/2015 (for delay) 1. For the reasons stated therein, the delay of 15 days in filing the appeal is condoned. 2. The application is disposed of. ITA 772/2015 3. This appeal by the Revenue under Section 260A of the Income Tax Act 1961 ("Act‟) is directed against the impugned order dated 6th January 2015 passed by the Income Tax Appellate Tribunal ("ITAT‟) in ITA No....

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....r Section 132 or the requisition under Section 132A, in the case of the other person (like the Assessee in the present case) "such date will be the date of receiving the books of account or documents or assets seized or requisition by the Assessing Officer having jurisdiction over such other person. In the case of other person, the question of pendency and abatement of the proceedings of assessmen....

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....sumes jurisdiction under Section 153C with the receipt of the relevant seized material from the AO of the searched person. Also, a copy of the satisfaction received from the AO of the searched person in this regard would enable him to proceed further in the case of the other person under Section 153C. Though there is no statutory requirement for the AO of such other person to record any satisfacti....

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....AY 2009-10 was not valid, calls for no interference. No substantial question of law arises in the facts and circumstances of the present case." 6. Learned counsel for the Revenue sought to urge that one of the issues that still survives for consideration is whether the proviso to Section 153C (1) of the Act is confined to the second proviso to Section 153A (1) of the Act, and therefore, applies o....