2024 (5) TMI 1700

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....022, D. B. Civil Writ Petition No. 6302/2022 - -<br>Income Tax<br>HON&#39;BLE THE CHIEF JUSTICE MR. MANINDRA MOHAN SHRIVASTAVA AND HON&#39;BLE MR. JUSTICE BHUWAN GOYAL For the Petitioner(s): Mr. Prateek Kedawat. For the Respondent(s): Mr. Siddharth Bapna with Mr. Meyhul Mittal. ORDER 1. In all these petitions, the reopening of assessment as also consequent reassessment orders are under....

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....ent petition, the order of reopening assessment and reassessment has not been challenged on the aforesaid ground but on other grounds. He would further submit that in any case, what has been stated in Para 6 of the impugned order shows that the basis for reopening assessment is not merely confined to any incriminating material or information collected during search but other statements, which were....

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....d it has also been held that in case of person other than on whom search was conducted but material belonging or relating to such person was seized or requisitioned, A.O. has to proceed under Section 153-C. 4. Applying the aforesaid law, if we look in the impugned order, we are of the view that the basis for reopening was incriminating material collected during search and the statements which w....