TaxTMI 
TaxTMI 
2026 (10) TMI 47
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....ter referred to as 'the Act') by the Assessing Officer, DCIT, Central Circle-26, (hereinafter referred to as the 'AO') pertaining to Assessment Year (A.Y.) 2014-15. 2. The assessee has raised the following grounds of appeal "1. The Ld. AO erred in law and on facts in initiating the proceedings u/s 153C of the Act and the Ld. CIT(A) erred in confirming the action of the AO in the facts and circumstances of the case. 1.1 The Ld. AO erred in law and on facts in framing the assessment u/s 153C of the Act for the instant year and the Ld. CIT(A) erred in confirming the action of the AO in the facts and circumstances of the case. The instant year was also beyond the block period permissible in the facts of the case. 2....
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....nd of appeal." 3. Brief facts of the case are that the assessee company had filed its original return of income for A.Y. 2014-15 on 30.03.2016 declaring Nil income. Subsequently, during the course of a search conducted u/s 132 of the Act on Alankit Group of cases, it was found that the group was engaged in providing accommodation entries to different entities. Some incriminating documents in the name of the assessee were also found from the searched premises and, therefore, its case was centralized vide order u/s 127(1) of the Act dated 15.01.2024.] 3.1 On 29.06.2022, a notice u/s 153C was issued to the assessee in response to which return declaring Nil income was filed on 12.07.2022. Subsequently, the assessment was completed u/s ....
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....igh Courts and also of the coordinate benches in support of his arguments. 4.2 On the other hand, Ld. DR has submitted that the satisfaction note based on the seized material was recorded on 24.06.2022. The same was approved by the Joint Commissioner of Income Tax on 27.06.2022 and, vide F. No. DCIT (CC-28) / Misc./2022-23/819 dated 24.06.2022, the satisfaction note along with the related annexures / seized material was forwarded by the DCIT, Central Circle-28, New Delhi to the ITO, ward-16(3), New Delhi for initiating proceedings under section 153C. Notice dated 29.06.2022 was issued which fully with the requirements of section 153C and, therefore, the appeal of the assessee deserves to be dismissed. 5. We have heard the rival submis....