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2016 (5) TMI 1372 - AT - Income TaxLegality of notice under section 153C - whether the satisfaction note as prepared by the Assessing Officer of the searched person in the present case is as per law or not? - Held that:- There is nothing coming out of the satisfaction note that the seized documents belong to the assessee. Further, there is nothing which would indicate as to how the presumption which was to be raised against the person searched have been rebutted by the Assessing Officer. The satisfaction note does not at all display the reason or basis for the conclusion that the Assessing Officer is satisfied that these documents ‘belong’ to the assessee. The the ingredients of section 153C of the Act have been satisfied in the present case. - Decided in favour of assessee.
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