2025 (11) TMI 634

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.... Member For the Assessee : Sh. Paritosh Jain, Adv., Sh. Rajat Jain, CA & Sh. Akshat Jain, CA For the Revenue : Sh. Dayainder Singh Sidhu, CIT-DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: The instant batch of four appeals involves the twin assessee's herein M/s Elan Ltd. and M/s Elan Buildcon Pvt. Ltd. Both these assessee's have filed the respective appeals i.e. ITA No. 759/De....

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....ied out the search in question in M/s Elan Group on 29.05.2018. Learned CIT-DR vehemently submits that it was the said search which led to seizure of the corresponding incriminating material followed by section 153C satisfaction recorded in these twin assessee's cases on 19.01.2021. That being the case, there would be hardly any quarrel in light of PCIT vs. Jasjit Singh (2024) 336 CTR 634 (Delhi) ....

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....aryana-122001 party AP-6 & Ap-6A during the course of search belong to/contain information which relates M/s Elan Ltd. (PAN: AADCE3341G) and have a bearing on the determination of its total income. Hence, notice u/s 153C of the Income Tax Act, 1961 is being issued for A.Ys. 2013-14 to 2018-19 and notice u/s 143(2) for A.Y. 2019-20." 5. Faced with this situation, Mr. Sidhu vehemently argues that....

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....on in accordance with law. This is for the precise reason that the legislature has itself incorporated the foregoing former expression of "belongs to" as involving "any money, bullion, jewellery..........." etc. in subclause (a) and the latter category of "pertains to" or "relates to"; for any books of account or documents etc.; respectively. Learned CIT-DR couldn't rebut the clinching fact that t....