Electronic Records Valid as "Books of Accounts" Pre-Amendment; Unexplained Income Addition to Directors Reassessed.
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....Validity of assessment framed u/s 153C - Search conducted at secret office of searched person - Definition of "Books and Books of Accounts" u/s 2(12A) includes electronic/digital form - Amendment clarificatory, retrospective - Printouts include PDF copies - Information stored in electromagnetic devices like pen drive, hard disk qualified as books of accounts even before amendment. Jurisdictional error invoking Section 153C rejected. Period of limitation - One year from date documents handed over/deemed handed over to assessing officer of other person, i.e., 31.03.2024. Satisfaction notes issued in time. Notices u/s 153C preceded satisfaction notes. No time lag between 31.03.2022 and satisfaction note dates. Incriminating material unearthed..........
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