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2019 (2) TMI 630 - AT - Income TaxAssessment u/s 153C - assumption of jurisdiction by the A.O. under section 153C - proof of incriminating material as found during the course of search - Held that:- Considering the facts of the case in the light of satisfaction note dated 22nd January 2014 reproduced above, it is clear that the only incriminating documents relates to the assessee was balance sheet and profit and loss account as on 31st March 2010 which would not relate to assessment years under appeals i.e., A.Ys. 2006-2007 to 2008-2009. Thus, no incriminating material was found during the course of search so as to proceed against the assessee under section 153C of the Income Tax Act. It is a general satisfaction recorded, therefore, A.O. was not justified in proceeding against the assessee under section 153C of the I.T. Act, 1961. - Decided in favour of assessee
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