2022 (10) TMI 1119

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....Income-tax Act, 1961 ('Act' for short) by assessees viz., Karthik Krishna and his sister Kavya Krishna - since deceased represented by her legal representative - mother viz., Smt.Rajyalakshmi. 2. Assessees' case is, a search and seizure was conducted in the premises of their mother - Smt. Rajyalakshmi on 26.08.2008. According to the Revenue, the gift deed in the form of declaration whereunder a sum of Rs.1.50 Crore each was gifted in favour of these two assessees. The jurisdictional Officer issued notice under Section 153C of the Act to the assessees and completed assessment holding that a sum of Rs.1.50 Crore each in the hands of the assessees was undisclosed income. The Commissioner of Appeals and Income-tax Appellate Tribu....

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....e is by assessees' uncle, which is exempted from tax. He contended that Muniswamy had explained the source of income viz., his bank accounts held with Axis Bank, HDFC Bank and Vijaya Bank from where he had transferred money through cheque, in favour of the assessees. 5. Shri Parathasarathi, concluded his arguments contending that, unless it is demonstrated by the Revenue that the Searching Officer had recorded his satisfaction, the jurisdictional Assessing Officer cannot initiate proceedings under Section 153C of the Act. 6. Shri E.I. Sanmathi, learned Advocate for the Revenue argued opposing the appeals and submitted that Muniswamy had deposed before the Assessing Officer that he had no source of income. Therefore, nothing remain....