2026 (4) TMI 458

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.... Sh. Sanjeev Kaushal, CIT, DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the order dated 09.09.2025 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/250/2025-26/1080473966(1) arising out of the assessment order dated 28.02.2025 u/s 15....

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....ng ld. AR has placed on record at page No. 55-70 the copy of assessment u/s 153A r.w.s 143(3) of the Act concluded on 30.09.2021 in the case of Sushen Mohan Gupta. Now admittedly search and seizure operation was conducted on 02.01.2020 and subsequent dates on Sushen Mohan Gupta & others group of cases at different business and residential premises of the group and the case of present assessee was ....

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....ge No. 25-29 satisfaction note recorded by the AO searched person on 08.03.2023 is provided wherein name of the group search is mentioned as Sushen Mohan Gupta and others and date of search is mentioned as 02.01.2020. Name and address of the other person to whom seized assets/papers belong is mentioned of present assessee. 7. Thus, it is quite apparent that while assessment in case of Sushen Mo....