2022 (10) TMI 840

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.... engaged in the business of brokers/marketing related activities. The A.O. noted that a search seizure operation under section 132 of the I.T. Act, 1961 was conducted on 26.09.2014 on the premises of the assessee comprising KDP/MGI group of cases. Subsequently, notice under section 153C of the I.T. Act, 1961 was issued on 16.09.2016 after recording satisfaction note. In response to the aforesaid notice, assessee electronically filed its return of income on 11.10.2016 declaring total income at Rs.318/-. Thereafter, the case was taken-up for scrutiny and consequently, assessment was framed under section 153C r.w.s. 143(3) of the I.T. Act, 1961 vide order dated 30.12.2016 and total income of the assessee company was determined at Rs.7,85,00,32....

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....tio of the decision in the case of RRJ Securities (supra) would not be applicable to the facts of the present case for the reason that the A.O. of the searched person and the assessee are the same and, therefore, the period of six assessment years should be considered from the date of search. 5. The Learned Counsel for the Assessee, on the other hand, supported the order of the Ld. CIT(A). 6. We have heard the Learned Representatives of both the parties and perused the material on record. The Revenue in the present appeal is challenging the action of Ld. CIT(A) in annulling the assessment framed by A.O. under section 153C of the I.T. Act, 1961. We find that Ld. CIT(A) after considering the submissions of the assessee, the remand repor....