2023 (3) TMI 1408

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....ndent : Gaurav Mahajan ORDER 1. Heard Sri Amit Mahajan, learned counsel for the assessee and Sri Manu Ghildyal, learned counsel for the revenue. 2. Challenge has been raised to the notice dated 04.02.2022 issued by the Assessing Authority of the petitioner under Section 153-C of the Income Tax Act, 1948 (hereinafter referred to as the 'Act') for A.Y. 2015-16. 3. Contention of learned c....

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....ed, such loose papers cannot form the basis for initiation of proceeding under Section 153-C of the Act. 5. On the other hand, learned counsel for the revenue would contend, the provision of Section 153-C(3) of the Act would not apply to the case of the petitioner inasmuch as that provision applies to the person searched which in the present case is the Saloni Group. Alternatively, that plea is a....