2026 (5) TMI 1392

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.... the Appellant : Sh. Amit Goel, CA & Sh. Pranav Yadav, Adv. For the Respondent: Ms. Monika Singh, CIT-DR ORDER Per Satbeer Singh Godara, Judicial Member: These twin assessees M/s Bhartiya International Ltd. and M/ s Avni Polymers Pvt. Ltd. have filed their respective three appeals i.e. ITA Nos. 5413, 5414 & 5415/Del/2025 for Assessment Years 2018-19 & 2019-20, arising against the CIT(A....

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....on to M/s K. K. Spun Group cases on 23.03.2021. There is further no denial to the fact that the learned assessing authority(ies) thereafter recorded their identical section 153C satisfaction that the corresponding documentary evidence found/ seized during the course of the above search infact "belonged to" both these assessees so as to proceed against them. 4. It is at this stage that the learn....

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....nd foremost substantive ground/legal arguments herein that both the learned lower authorities have erred in law and on facts in framing the impugned section 153C r.w.s. 143(3) assessment dated 30.03.2024; in furtherance to the searched party's Assessing Officer's satisfaction dated 25.03.2023 and his assessing authority on the very date, as the case may be, which has been wrongly upheld in the low....

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....orded that the corresponding seized document during the course of search "belonged to" the assessee/appellant who happens to be the third party u/s. 153C of the Act. 6. Faced with this situation, the Revenue could once again not dispute that section 153C(1)(a) stipulates the category of the seized material as "any money, bullion, jewellery .. ... "which could be held as belonging to a thi....