2024 (2) TMI 1579

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....av Mahajan ORDER 1. Heard Shri Suyash Agarwal, learned counsel for the petitioner and Shri Ashish Agarwal, learned counsel for the revenue authority. 2. Challenge has been raised to the assessment proceedings initiated against the petitioner for the Assessment Year 2011-12 under Section 153-C of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). 3. Principally, it has bee....

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....ority was made available to the petitioner. Further objections have been raised that arising from the search dated 18.10.2019, the date of Satisfaction Note being of the year 2022, no assessment could have been sought beyond the period of ten years from the date of requisition made. Third, it has been submitted that only incriminating material (referable to the present petitioner) were for two Ass....

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....alls under discretionary jurisdiction to be exercised at appropriate stage, considering the availability of statutory remedies. Delay and laches may deny such discretionary remedy to the petitioner. 8. Applying that test, we find that petitioner has raised objection to assumption of jurisdiction on 13.08.2022. That objection was rejected by a written order dated 28.09.2022. The Satisfaction Note ....