2025 (8) TMI 1249

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....ment Represented : Shri Subhash Kumar, Sr. DR ORDER PER SATBEER SINGH GODARA J.M: This Revenue's appeal for assessment year 2011-12 arises against Commissioner of Income-tax (Appeals)-28, New Delhi' order dated 19.05.2023 in case no. 26/10134/2019-20 in proceedings u/s 153C read with section 143(3) of the Income-tax Act, 1961, hereinafter referred to as the 'Act'. 2. It emerges at the ....

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....statutory expression "and for the relevant assessment year/(s) referred to in sub-section (1) of section 153A" and therefore it falls within the statutory block period. 4. We have given our thoughtful consideration to the instant first and foremost legal issue between the parties. There would be hardly any dispute that section 153C(1) 1st proviso adopts the date of initiation of search in such ....

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....ion, there has to be a clear cut indication therein that the income having escaped ....... must satisfy the threshold limit of Rs. fifty lakhs. We thus accept the assessee's instant legal ground as the learned Assessing Officer; be that in case of the searched assessee as well as the appellant herein, had nowhere recorded any such satisfaction invoking the pecuniary limit of Rs. fifty lakhs and th....

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....stipulates that such document could only "pertains or "pertain" to/or any information contained therein could "relevant to" any third person other than the searched assessee. This is for the precise reason that the legislature's instant amendment had substituted the earlier provision wherein such seized document(s) could also belong to persons other than the searched assessee. We thus conclude tha....