2025 (5) TMI 1248

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....53C of the Income Tax Act, 1961 [the Act] in respect of Assessment Year [AY] 2015-16. The Petitioner states that the proceedings pursuant to the impugned notice dated 19.12.2023 are barred by limitation, as no assessment order can now be passed, as the time period stipulated for passing an assessment order, has elapsed. The Petitioner's challenge rests on Section 153B of the Act, which stipulates that an assessment order pursuant to a notice under Section 153C is required to be passed within a period of twelve months from the end of the financial year in which the said notice was issued. The Petitioner claims that since the said period has elapsed, the Revenue is required to be restrained from proceeding further with the impugned notice. 2....

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....or, other valuable article or thing) or papers (books of accounts or documents) seized u/s 132/ requisitioned u/s 132A. Sh. Alok Kumar Agarwal, Sh. Ankit Agarwal, M/s Alankit Limited, M/s. Alankit Assignments Limited 3 PAN of searched assessee Sh. Alok Kumar Agarwal, (PAN: AAJPA1283A) Sh. Ankit Agarwal, (PAN: AGAPA5363L) M/s Alankit Limited, (PAN: AAACE1288P) M/s Alankit Assignments Limited (PAN: AAACA9483E) 4 Name and address of the other person to whom seized assets /papers belong. M/s Landcraft Developers Pvt. Ltd. 5 PAN of other person AABCL1391F 6 Identification of the seized asset/papers which in the opinion of AO of the searched assessee (S. No. 2), belong to the other person (S. No. 4) Annexure A-31 as HP Laptop w....

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....1. 7 Assessment years involved. A.Y. 2010-11 to 2020-21 *Copy of relevant Panchnama shall be integral part of satisfaction note. In view of the above, I am satisfied that these documents also contain information which relates to above referred 'other person' and have a bearing on the determination of its total income. Accordingly, these documents are handed over to the AO of other person, for necessary action in the case of the above referred 'other person' under section 153C of the I.T. Act 1961 for the relevant assessment years as per the seized documents." [emphasis added] 6. As noted above, the note clearly records that the documents and information relating to the Petitioner were handed over to the AO having j....