2026 (4) TMI 476

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....t : Sh. Jitender Singh, CIT, DR ORDER PER ANUBHAV SHARMA, JM: This appeal preferred by the assessee against the order dated 13.08.2025 of Ld. Commissioner of Income Tax, (Appeal)-26, Delhi (hereinafter referred to as the First Appellate Authority or 'the ld. FAA' for short) in DIN & Order No : ITBA/APL/S/250/2025- 26/1079588703(1)arising out of the assessment order dated 30.01.2024 u/s 15....

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....s 132 of the Income Tax Act, 1961 carried out on 03.02.2021 and on subsequent dates at different business and residential premises of Sh. Samir Modi & Smt. Shivani Modi Group of cases. Various incriminating papers/documents were found and seized during the course of search & seizure operation. Further satisfaction note was recorded on 21.03.2023 by the AO of person searched and proceedings u/s 153....

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....ited. However, it can be seen that the law was amended w.e.f. 1.4.2021 by Finance Act, 2021, and as per the amended law, no action u/s 153C of the Act could be taken on the searchcarried out on or after 01.04.2021.The assessment should be either u/s 143(3) of the Act or should be completed u/s 148 of the Act as per the amended provisions. Reliance for this can be placed on the decision of a bench ....