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2015 (4) TMI 545 - AT - Income TaxValidity of proceedings u/s 153 - Held that:- After considering the satisfaction note and the assessment order of the AO for AY 2009-10, it is evident that the seized document belonged to AY 2009-10 and not to AY 2005-06 & 2006-07. Therefore, in our opinion, there is no necessity of sending the matter back to the file of AO for verification of the year to which the seized document belonged. In view of above, we respectfully following the decisions of Hon’ble Jurisdictional High Court in the case of SSP Aviation Ltd. (2012 (4) TMI 335 - DELHI HIGH COURT ) and Devi Dayal Petro Chemical Pvt. Ltd. (2014 (10) TMI 216 - ITAT DELHI), hold that the proceedings u/s 153C was not validly initiated for AY 2005-06 and 2006-07 because the seized document did not belong to these assessment years. We, therefore, quash the proceedings initiated u/s 153C and consequently assessment orders passed in pursuance thereof. - Decided in favour of assessee.
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