2022 (9) TMI 1518

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....t : Mr. Smarajit Roy Chowdhury, Adv., Mr. Subhas Agarwal, Adv. For the Respondent : Mr. Brijesh Kumar Singh, Adv. ORDER Re: GA 1/2021 The Court: We have heard Mr. Smarajit Roy Chowdhury, learned standing counsel appearing for the appellant/revenue and Mr. Subhas Agarwal, learned advocate assisted by Mr. Brijesh Kumar Singh, learned advocate for the respondent/assessee. 2. There is a....

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....ch was required to be covered under proceeding u/s 153C of the Income Tax Act, 1961? B) Whether the decision of Income Tax Appellate Tribunal is erred under law as the jurisdiction of the searched group (DOS 06.03.2014) and the seized materials were with the Assessing Officer and the assessee's jurisdiction has been transferred in to the Assessing Officer's jurisdiction vide order u/s 127....

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.... to how this year period should be calculated. Learned Tribunal rightly took note of the decision in the case of SSP Aviation Ltd.-vs- Deputy Commissioner of Income Tax reported in [2012] 20 taxmann.com 214 (Delhi), wherein it was held as follows: "14. ... ... For instance, in the present case, with reference to the Puri Group of Companies, such date will be 5.1.2009. However, in the case....