2025 (12) TMI 1698

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.... PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2020-21, arises against the Principal Commissioner of Income Tax (Central) [in short, the "PCIT"], Delhi's-3 DIN and order no. ITBA/REV/F/REV5/2024-25/1075307839(1), dated 30.03.2025 involving proceedings under section 153C of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). Cased called twice. None appe....

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....nt under section 153C of the Act involving an "unabated" assessment year wherein any addition could be made only on the basis of incriminating material found/seized during the course of search only in light of PCIT Vs. Abhisar Buildwell Pvt. Ltd. (2023) 454 ITR 212 (SC). We further make it clear that the relevant date of section 153C notice in the assessee's case was 09.02.2024; and, therefore, th....