2026 (4) TMI 457

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.... Sh. Ayush Garg, CA For the Respondent : Sh. Jitender Singh, CIT, DR ORDER PER ANUBHAV SHARMA, JM: These appeals preferred by the Assessee against the orders of the Ld. Commissioner of Income-tax (Appeals) (hereinafter referred to as the First Appellate Authority or 'the ld. FAA' for short) in appeals filed before him against the orders of the ld. Assessing Officer (hereinafter referre....

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.... ld. Counsel has primarily stressed for disposal of ground No. 4 by way of which assumption of jurisdiction u/s 153C have been challenged. As for convenience we reproduce ground No. 4 below: "4. On the facts and circumstances of the case, the proceedings under section 153C initiated against the assessee are beyond the permissible period as held by the Hon'ble Supreme Court in the case....

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....f the present assessee it is recorded that Dheeraj Dhar Gupta and Shri Dhar Gupta were subjected to search as part of Sushen Mohan Gupta and others on 02.01.2020 and during the course of same incriminating documents were found which became subject to all the additions. 5. Now at page No. 6-7 copy of satisfaction recorded in the case of assessee is provided wherein name of the group search is me....

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....tion to the decision of Hon'ble Supreme Court in the case of CIT-III Vs. M/s Calcutta Knitwears Ludhiana (2014) 362 ITR 673 (SC), dated 12.03.2014 which has been also considered for issuing instructions by CBDT vide Circular No. 24/2015 date 31.12.2015 and the same provide that there has to be reasonable time for recording satisfaction and in any case the same cannot be beyond the period of 4 mont....