2026 (1) TMI 244

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....Shobha Bansal, CA ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/APL/S/250/2024-25/1072270642(1), dated 17.01.2025 involving proceedings under section 153A r.w.s. 143(3) of the Income-tax Act, 1961 (he....

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..... 4. We have given out thoughtful consideration to the asseessee's instant first and foremost legal argument. We find reason to accept the same. This is for the precise reason that apart from the impugned search dated 27.02.2020 carried out on M/s. Raipur Group of cases which followed the Assessing Officer's section 153A notice, learned departmental authorities appear to have issued an yet anot....

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....dding of Rs. 1,36,03,896/- as well as latter twin cash sums of Rs. 51,60,520/- and Rs. 51,45,000/- as his "unexplained" money under section 69A r.w.s. 115BBE of the Act, in assessment order and upheld in the lower appellate discussion. 7. We notice from a perusal of the case records that the above former as well as the last sum are based on the relevant evidence collected from the official prem....