2025 (5) TMI 2167

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.... respect of Assessment Year [AY] 2013- 14. 2. On 23.03.2021, a search was conducted under Section 132 of the Act in the case of Sh. Parasmal Jain including the petitioner. It is the petitioner's contention that no incriminating material pertaining to the searched persons was found during the said search thus, no further proceedings were warranted. 3. However, subsequently, proceedings under Section 153A of the Act were initiated against the petitioner by issuance of a notice dated 07.12.2021 issued under Section 153A of the Act. Pursuant to the said notice, the petitioner had filed its return of income for AY 2012-13, declaring an income of Rs.1,12,39,280/-. The Assessing Officer [AO] proceeded with an assessment order dated 31.03.202....

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....he rejection of such a prayer by the Revenue in the PCIT v. Abhisar Buildwell Pvt. Ltd. (supra). 7. On 28.03.2024, the AO rejected the petitioner's reply, and passed an order under Section 148A(d) of the Act, deeming it a fit case for reopening and further issued a notice under Section 148 of the Act, asserting that the proceedings were within the limitation period by invoking Section 150 of the Act. 8. In ARN Infrastructures India Ltd. v. Assistant Commissioner of Income Tax Central Circle-28 Delhi & Ors.: Neutral Citation No. :2024:DHC:7423-DB, this court held as under: "38. It is pertinent to note that a reference to Sections 147 and 148 of the Act in Abhisar Buildwell firstly appears in paragraph 33 of the report and....