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2022 (4) TMI 27 - AT - Income TaxAssessment u/s 153A - valid satisfaction recorded u/s. 153C or not ? - specified incriminating seized material "belongs to" a person other than the searched parties - HELD THAT:- DR could hardly rebut the fact that the Assessing Officer herein had only recorded the corresponding seized material as "relates to" the assessee whereas the said statutory expression stood inserted in the Act w.e.f. 1.6.2015 only. We are dealing with the search in question dated 11.03.2010 in M/s. MBS Jewellers (P) Ltd. and that the corresponding satisfaction on the Assessing Officer's part had to be only to the effect that the specified incriminating seized material "belongs to" a person other than the searched parties. Coupled with this, learned counsel has already filed a copy of the tribunal's order in M/s. Ashi Plywood Industries relating to the very search that the Assessing Officer had not recorded a valid satisfaction u/s. 153C as well. We thus follow judicial consistency to affirm the CIT(A)'s identical lower appellate findings in the absence of any distinction on facts and circumstances involved herein.
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