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2025 (6) TMI 163

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....relation to the assessment year 2014-15. 2. The prelude to availing the benefits under the aforesaid Scheme pertains to the processing of an application declaring the income under Section 143 (1) of the Income Tax Act, 1961 for the assessment year 2014-15, but on the basis of an information with regard to certain claims, the survey operation under Section 133A of the Income Tax Act was conducted by the DDIT (Inv.), Rourkela at the registered address of the two companies in which the assessee appears to be a Managing Director and the report so submitted was forwarded for a necessary action to be taken in this regard. 3. By an assessment order dated 29th May, 2023, the assessing officer treated the consideration received on account of sale ....

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....is of search initiated under section 132 or section 132A of the Income-tax Act; (ii) relating to an assessment year in respect of which prosecution has been instituted on or before the date of filing of declaration; (iii) relating to any undisclosed income from a source located outside India or undisclosed asset located outside India; (iv) relating to an assessment or reassessment made on the basis of information received under an agreement referred to in section 90 or section 90A of the Incometax Act, if it relates to any tax arrear; (b) to any person in respect of whom an order of detention has been made under the provisions of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 on or before t....

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....s been instituted on or before the filing of the declaration or such person has been convicted of any such of offence punishable under any of those Acts; (d) to any person in respect of whom prosecution has been initiated by an income-lax authority for any offence punishable under the provisions of the Bharatiya Nyaya Sanhita, 2023 or for the purpose of enforcement of any civil liability under any law for the time being in force, on or before the filing of the declaration or such person has been convicted of any such offence consequent to the prosecution initiated by an income-tax authority; (e) to any person notified under section 3 of the Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992 on or before....