2025 (5) TMI 2218

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....hat Jain, CA For the Revenue : Ms. Meenakshi Dohare, CIT(DR) ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Department of Revenue against the order of the Commissioner of Income Tax (Appeals)-26, New Delhi ('Ld. CIT(A)' for short)- dated 16/08/2024 pertaining to the Assessment Year 2013-14. 2. Brief facts of the case are that, a search and seizure operation unde....

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....rtain additions. 3. Aggrieved by the assessment order dated 31/12/2022, the Assessee preferred an Appeal before the Ld. CIT(A). The Ld. CIT(A) vide order dated 16/08/2024, allowed the Appeal filed by the Assessee by relying on Judgment of Ld. CIT Vs. RRJ Securities 380 ITR 612, Ld. CIT Vs. Singbad Technical Education Society: 397 ITR 344 and PCITVs. Central-1, Ojjus Medicare Pvt. Ltd. [2024] (4....

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..... As per the provision of Section 153C of the Act, the date of satisfaction and handing over the seized material would be the deemed date of search in so far as the Assessee is concerned. Therefore, action can be taken u/s 153C of the Act in respect of six Assessment Years from preceding year in which satisfaction was recorded, accordingly, the notice u/s 153C of the Act can be issued for Assessme....