2025 (7) TMI 28

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....br>Shri Inturi Rama Rao, Accountant Member And Shri Prakash Chand Yadav, Judicial Member For the Appellant : Sri.Arun Raj S, Advocate For the Respondent : Smt.Leena Lal, Sr.AR ORDER PER PRAKASH CHAND YADAV, JM : These appeals filed by the assessee are directed against different orders of the Commissioner of Income-tax (Appeals)-3, Kochi ["CIT(A)" for short], all dated 24.10.2024, co....

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....e appellant was stated to have been found and seized. Based on such incriminating material, the Assessing Officer ("the AO" hereinafter) issued notice u/s. 153C of the Act on 08.05.2021. In response to the notice issued u/s. 153C of the Act, the appellant did not file any return of income. 4. Against the said return of income, the assessment was completed by the AO vide order dated 6th March, 2....

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....in the case of Sir Shadilal Sugar & General Mills Ltd. v. CIT. The AO rejecting the above explanation of the appellant and placing the decision of the Hon'ble Supreme Court in the case of MAK Data Private Limited v. CIT held that the appellant is guilty of concealing particulars of income and levied penalty of Rs. 2,21,692vide order dated 23rd September, 2022. 5. Being aggrieved by the above or....

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....on to the appellant herein. Merely because the appellant has disclosed additional income in response to notice u/s. 153C of the Act, it cannot lead to the conclusion that the appellant is guilty of concealing the particular of income or guilty of concealment of income. It is the case of assessment made u/s. 153C of the Act, pursuant to the initiation of search and seizure in the case of a third pe....