2022 (5) TMI 1342

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....Shri Amit Goel, CA, Shri Nippun Mittal, CA For the Department : Shri Ishtiyaque Ahmed, CIT- DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- These two separate appeals by the Revenue are preferred against the common order of the ld. CIT(A)-IV, Kanpur dated 25.02.2019 pertaining to Assessment Years 2011-12 and 2014-15. 2. The grievance of the revenue read as under: "1. Whethe....

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....ished after detailed investigation of facts or law. 3. Whether on facts and circumstances of the case and in law, the Ld. CIT (A) erred in applying the decision of the Hon'ble Supreme Court in the case of M/s Sinhgad Technical Education Society, which was distinguishable as the same pertained to period prior to 01.04.2005 whereas after amendment w.e.f. 01.04.2005, 153C notice can be i....

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....nce and brevity. 4. Briefly stated, the facts of the case are that a search and seizure operation u/s 132 of the Income-tax Act, 1961 [hereinafter referred to as 'The Act'] was conducted on 11.11.2014 on the premises of the assessee comprising Apple group of cases. Accordingly, statutory notices were issued and served upon the assessee. 5. Assessment for Assessment Year 2011-12 was c....

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.... the case of Singhad Technical Education Society [supra] squarely apply and cancelled the assessment. 8. Before us, the ld. DR strongly supported the findings of the Assessing Officer. 9. Per contra, the ld. counsel for the assessee reiterated what has been stated before the lower authorities. 10. We have carefully perused the orders of the authorities below. The impugned assessment order....