2025 (5) TMI 364

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.... alia, impugning the separate notices dated 26.12.2019 [impugned notices] issued under Section 153C of the Income Tax Act, 1961 [the Act] in respect of Assessment Years [AYs] 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, and 2017-18. The petitioner also impugns an order dated 17.03.2021 [impugned order] passed by the Assessing Officer [AO] disposing of the petitioner's objections and prays that the respondent be restrained from proceeding further pursuant to the aforesaid impugned notices. 2. The petitioner seeks to impugn the notices, inter alia, on the ground that no incriminating material was found pursuant to the search conducted under Section 132 of the Act or a requisition made under Section 132A of the Act in respect of any other per....

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....thirty-one parcels, two parcels contained bills and therefore, no questions were raised regarding the said parcels. Further enquiry was conducted in respect of the remaining parcels and notices under Section 131 of the Act were issued to the aforesaid two individuals. Statements were also recorded under Section 131 (1) (a) of the Act. The said proceedings were converted into a search under Section 132 of the Act on the warrant of authorization being received from the concerned authorities. During the search, the statement of Sh. Suresh Kumar Jaikishan Bangarwa was recorded under Section 132 (4) of the Act. During the search proceedings a parcel (parcel no. J-9) containing Fine Gold weighing 49 gms. valued at Rs. 1,32,288/- was seized. It wa....