TaxTMI 
TaxTMI 
2026 (9) TMI 1446
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..... Akhilesh Kumar, Adv., Sh. VipinGarg, Adv. And Sh. Monu Singh, Adv. For the Respondent : Ms. Ashok Gautam, CIT, DR ORDER PER ANUBHAV SHARMA, JM: These appeals preferred by the Assessee against the orders of the Ld. Commissioner of Income Tax (Appeals)-25, New Delhi (hereinafter referred to as the First Appellate Authority or 'the ld. FAA' for short) in appeals filed before him against....
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....aised as additional ground at the time of hearing and same being admissible under Rule 11 and relying decision of Hon'ble Punjab and Haryana High Court in VMT Spinning Co. Ltd. Vs. CIT; [2016] 74 taxmann.com 33 (P&H), the ground was admitted. The ld. Counsel contested and challenged the impugned assessment order on wrongful assumption of jurisdiction wherein assessment has been completed u/s 153C ....
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....see the satisfaction note has been recorded on 05.08.2022, therefore, date of search as per the decision of Hon'ble Supreme Court in Jasjit Singh [2023] 458 ITR 437 (SC), the deemed search year becomes 2022-23 and therefore, in terms of Section 153C(3) of the Act, the proceedings u/s 153C could not have been conducted and the revenue could have resorted to proceedings of Section 147 of the Act. Th....
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....faction should be individually granted. 7. However, we find that in the satisfaction note copy of which is available in paper book 96-97, there is merely reference of some digital devices and electronic evidence have found, however, there is no mention of any adverse material qua, assessee indicating how this material is bearing on the escapement of income with regard to years involved for reop....