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2015 (2) TMI 11 - HC - Income TaxScope of Section 153C - whether it enables the assessing officer to issue notice to third parties, on the basis of the satisfaction that “any money, bullion, any jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person” referred to in section 153A, i.e. the person searched, is wide enough to lead to a notice only on the basis of entries in some documents? - Held that:- ITAT should render specific findings as to the status of the documents and in that sense, connect with the concerned assessee’s third parties who were issued notice under Section 153C, and not merely the general nature of the documents in the form of production figures or amounts tabulated in a chart. This would give a clearer picture as to whether any document or material seized during the course of the proceedings belonged to any of the assessees. Thus remit the matter for reconsideration on the lines indicated above. The ITAT shall refer to the material in entirety in respect of each assessee and render specific findings on this aspect. - Decided in favour of revenue for statistical purposes.
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