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2019 (6) TMI 446 - BOMBAY HIGH COURTAssessment u/s 153C - entertained the factual aspect in Writ Petition - HELD THAT:- We would not like to carry out thread bare inquiry by going into the factual aspects of sufficiency of material in order to initiate proceedings u/s 153C or of co-relating the incriminating material found during search on the basis of which additions are made in the assessment orders. The assessment orders prima facie would suggest that the Assessing Officer is silent on this issue of co-relation between addition made and the material found during such search. In the case of Commissioner of Income Tax V/s. Vijaybhai N. Chandrani [2013 (7) TMI 740 - SUPREME COURT ] Supreme Court reversed the Judgment of the High Court observing that the High Court ought not to have entertained the Writ Petition and should have directed the Assessee to file Reply to the Notices and upon receipt of a decision from the assessing authority, if for any reason it is aggrieved by the said decision, to question the same before the forum provided under the Act. Having perused the material on record and in particular the orders of assessment passed by the Assessing Officer pursuant to the Notices u/s 153C, while relegating the Petitioner to the appeal remedy, we would like to make an interim formula in the peculiar facts of the case. It would be open for the Petitioner to file Appeals against the assessment orders. If such Appeals are filed before 25th June, 2019, the same shall be entertained on merits without having reference to limitation.
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