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2026 (9) TMI 2034

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...., CIT (DR) ORDER PER MADHUMITA ROY, JM: The instant appeal filed by the assessee is directed against the order dated 13/12/2024 passed by the Ld. Commissioner of Income-tax (Appeals)-30, Delhi under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') arising out of the Assessment Order dated 28/12/2022 passed by the Assessment Unit, Income-tax Department under S....

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....assessee which was further confirmed by the First Appellate Authority. Hence, the instant appeal before us. 3. It is the case of the Assessee that the satisfaction was recorded by the Ld. AO of the Assessee on 11.05.2022 which is falling in the F.Y 2022-23 relevant to A.Y 2023-24.As per first proviso to Section 153C (1) the date of search would be the date of satisfaction recorded by the Ld. AO....

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....ter, the assessment for the year under consideration is without jurisdiction and thus, liable to be quashed. 5. The Ld. DR relied upon the order passed by the authorities below. 6. In this regard, we have considered the Judgment relied upon by the Ld. AR passed in the matter of Jasjit Singh by the Hon'ble Supreme Court, reported in 2023 (10) TMI 572 and the Judgment passed by the Co-ordinate....