2026 (2) TMI 420

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....ing to Assessment Year 2021-22. 2. Brief facts of the case are that assessee has filed her return of income on 14.03.2022, declaring total income of INR 4,13,910/-. A search and seizure operation was carried out in the case of "Sanjay Jain and Mehtas" on 26.10.2020 wherein during the course of search, various incriminating material / documents were found and seized. Thereafter, AO of the person searched has supplied the material after recording his satisfaction that certain documents pertained to the assessee. Thereafter, the AO of the assessee has recorded his satisfaction on 24.05.2022 and initiated the proceedings u/s 153C of the Act for Assessment Years 2015-16 to 2021-22. Notice u/s 143(2) of the Act was issued on 24.05.2022 for the....

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.... have valid DIN. 5. On the facts and circumstances of the case and in law, the CIT(A) erred in confirming the addition made by the assessing officer of Rs. 76,65,660/- on account of alleged unexplained money u/s 69A r.w.s 115BBE of the Act, and, therefore, the addition made by the AO is liable to be deleted. 6. On the facts and circumstances of the case and in law, the assessment order passed by the assessing officer is contrary to the provisions of section 153D of the Income Tax Act, 1961. 7. On the facts and circumstances of the case and in law, the CIT (A) erred in passing the order without providing proper opportunity of being heard. 8. On the facts and circumstances of the case and in law, the CIT(A)....

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....pta v. ACIT, Central Circle 04, Delhi 7. On the other hand, Ld. Sr.DR for the Revenue vehemently supported the orders of the lower authorities and submits that limitation of serving the notice u/s 143(2) of the Act was since not expired on the date of receiving books of accounts or documents or assets seized or re-acquisitioned by the AO having jurisdiction over the assessee. Therefore, in terms of the provisions of section 153C(2) of the Act, the AO has rightly issued the notice u/s 143(2) and subsequently, passed the order u/s 143(3) of the Act which deserves to be upheld. 8. Heard the contentions of both the parties and perused the material available on record. In the present case, admittedly, the satisfaction was recorded by the A....