2025 (10) TMI 93

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....the Assessee : Sh. Ved Jain, Adv and Ms. Uma Upadhyay, CA For the Revenue : Ms. Pooja Swaroop, CIT DR ORDER PER YOGESH KUMAR, U.S. JM: The present appeal and Cross Objection are filed by the Revenue and the Assessee respectively challenging the order of Ld. Commissioner of Income Tax (Appeals) ('Ld. CIT(A)' for short), New Delhi dated 13/11/2024 pertaining to Assessment Year 2011-12. ....

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....ought for dismissal of the Appeal. 4. We have heard both the parties and perused the material available on record. The Assessee has challenged the validity of passing the impugned assessment order itself. In the present case, a search has been carried out on 02/11/2017 at the premises of Sh. Rakesh Jain, the A.O. of the search person has recorded his satisfactions on 16/07/2021 and handed over ....

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....e of validity of the impugned assessment itself herein as the learned departmental authorities had carried out the search in question on 02.11.2017 followed by initiation of section 153C notice issued to the assessee on 01.02.2022 culminating in the impugned assessment framed in her case on 29.12.2022. 3. This being the clinching factual position, learned CIT(DR) could hardly dispute that the asse....