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2015 (7) TMI 1101 - HC - Income TaxNotice u/s 153C – Search and seizure u/s 132(1) – Satisfaction note - Held that:- Matter stands covered against the Revenue by virtue of the judgment of this Court in Pepsi India Holdings P. Ltd. v. ACIT (2014 (8) TMI 898 - DELHI HIGH COURT) wherein held Tthe finding of photocopies in the possession of a searched person does not necessarily mean and imply that they “belong” to the person who holds the originals - Possession of documents and possession of photocopies of documents are two separate things. The finding of photocopies in the possession of a searched person does not necessarily mean and imply that they “belong” to the person who holds the originals - Possession of documents and possession of photocopies of documents are two separate things - the ingredients of Section 153C of the Act have not been satisfied - thus, the notice issued u/s 153C is set aside – Decided in favour of Assessee.
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