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2022 (3) TMI 1566 - HC - Income TaxAssessment u/s 153C - As argued jurisdictional AO issued notice u/s 153C based on the information received from other AO, who searched other person - After receipt of notice, when petitioner submitted an application for supply of satisfaction recorded by the other Assessing Officer who searched third person, jurisdictional AO has forwarded reason / satisfaction recorded by him before issuing notice u/s 153C but grievance of petitioner is that jurisdictional AO has not supplied him satisfaction recorded by AO, who searched third person. HELD THAT:- When this Court put pin-pointed question to petitioner that under which provision, satisfaction recorded by AO who searched third person is to be supplied to Assessee, he submits that under the scheme of Act, Assessee is required to know the basis and reasons, on which, notice has been issued. Undisputedly, when Assessee has submitted an application before Assessing Officer, he supplied reasons recorded by him before issuance of notice u/s 153C. At this stage, Petitioner would submit that as per his information, Assessing Officer who searched third person has not recorded the satisfaction. In the opinion of this Court, this appears to be a factual dispute raised by learned counsel for petitioner, which can be very well considered and decided by Appellate Authority. The case laws, petitioner placed reliance are arising of order passed by Appellate Authority in an appeal challenging order of assessment, hence, we are not inclined to entertain this writ petition, particularly when during pendency of this petition, assessment order is already passed by Authority as the petitioner is having efficacious alternate statutory remedy of filing appeal under Section 246A.
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