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2021 (10) TMI 292 - HC - Income TaxAssessment u/s 153A - Need for recording satisfaction - HELD THAT:- Investment of the petitioner in the relevant year to the extent of ₹ 80.00 lakhs, may be that for some reason, the agreement could not be performed and the petitioner may have to resort to lodging of an FIR against the vendor named therein, but the aforesaid documents sufficiently reveal that the petitioner intended to acquire an asset worth ₹ 80.00 lakhs in the relevant year and the said asset has escaped assessment. The said assessment/satisfaction of the Assessing Authority may not be correct or justified, nonetheless, he was possessed of the documents to form an opinion that the income worth over ₹ 50.00 lakhs or above has escaped assessment - not only he was possessed of the relevant documents but has also recorded his satisfaction regarding escapement of assessment to the tune of over ₹ 50.00 lakhs. Accordingly, it is not a case where ex facie it can be said that the notice is without jurisdiction. It may be relevant to note that in response to the aforesaid notices, the petitioner has already filed revised returns and the matter is pending assessment. Once the petitioner has already filed revised returns, he has accepted or acquiesced to the notices and, as such, is estopped from challenging the same.
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