2025 (9) TMI 1396

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....y Garg, CA For the Respondent : Sh. Mahesh Kumar, CIT, DR ORDER PER MADHUMITA ROY, JM: Both the appeals filed by the assessee are directed against the common order passed by the Ld. CIT(A)-30, Delhi dated 31.01.2024 arising out of the common Assessment Order dated 31.12.2022 passed by the Ld. DCIT, CC-31, New Delhi, under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred....

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....efrom whatsapp images related to construction expenses were found during the whatsapp chat of Praveen Kumar Jain and Vaibhav Jain; cash components were found to have been involved for construction of the property lying and situated at C-192, Nirman Vihar. Satisfaction notes dated 30.07.2022 and 30.12.2022 were duly recorded by the DCIT, CC-3, Delhi in the case of searched person Shri Praveen Kumar....

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.... to 2021-22 whereas it is the trite law that the date of recording of satisfaction under Section 153C will be deemed date of search which is 30.12.2022 in the present case six years period would be reckoned from this date i.e. 30.12.2022. 5. Accordingly, assessment year relevant for previous year in which search was conducted in the present year will be A.Y. 2023-24 and the relevant for the pre....