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2022 (1) TMI 541 - GUJARAT HIGH COURTAssessment u/s 153C - principal argument canvassed is that Section-153(C) can be invoked with respect to a particular seized document vis-a-vis the transaction - HELD THAT:- So far as the other 05 transactions are concerned, they are not part of the documents seized during the course of the search premises of Dr. Dilip Patel - no incriminating materials was recovered with respect to the particular assessment year i.e.2017-18, for which the information is sought for. It is also submitted that there is no incriminating material found with respect to these 05 other adjoining parcels of land. Our attention was drawn to the reasonings assigned by the Assessing Officer while overruling the objections raised by the writ-applicant. The Assessing Officer has said that as the 05 other parcels of land are adjacent to the land at revenue survey no.77/2/1, logically, it could be derived that the other five sellers must have been paid the amount commensurate to what had been paid to Dr. Dilip Patel. Let Notice be issued to the respondent, returnable on 24.01.2022.Let there be an ad-interim order in terms of Para-10(C). Direct service is permitted.
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