2025 (12) TMI 1504

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.... Singh Godara, Judicial Member And Shri Manish Agarwal, Accountant Member For the Assessee : Sh. Rohit Jain, Adv., Ms. Tejasvi Jain, CA And Sh. Shivam Gupta, CA For the Department : Ms. Amisha S. Gupta, CIT(DR) ORDER PER SATBEER SINGH GODARA, JM These four assessee's, namely, Sh. Vijay Anand Chaurasi, Sh. Rajiv Chaurasia, Sh. Navneet Chaurasia and Sh. Mayank Chaurasia have filed the....

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....ses on 15th and 27th January, 2020 lasting up to 2nd March, 2020. We notice that the said search thereafter led the Assessing Officer of the searched person(s) to record his satisfaction under section 153C of the Act against these assessee's; and, he accordingly forwarded the relevant seized material to their Assessing Officer(s). And that the assessee's Assessing Officer(s) in this manner then re....

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....e. Annexure A-1 to A-23 is being provided to Sh. Pramod Kumar Jaipuria to provide the replies on the content mentioned on the pages of Annexure A-1 to A-23. The reply should be furnished by 20/03/2023 positively." 4. We are informed that all this followed the learned Assessing Officer(s)' assessments framed in the assessee's cases on 30th March, 2023, inter alia, disallowing/adding identical tr....

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....ial as having any bearing in their respective cases. We thus are of the considered view that both the learned lower authorities have erred in law and on facts in disallowing/adding the assessee's travelling expenditure etc. without recording any satisfaction under section 153C of the Act which forms a condition precedent in light of PCIT Vs. Anand Kumar Jain HUF (2021) 133 taxmann.com 288 (Del), C....