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2022 (4) TMI 28 - ITAT HYDERABADAssessment u/s 153C - incriminating seized material found in search or not? - HELD THAT:- 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 AO's part had to be to the effect that the specified incriminating seized material "belongs to" a person other than the searched party. Coupled with this, learned Counsel has already filed a copy of the tribunal's order in M/s. Ashi Plywood Industries is the very search that the Assessing Officer had not recorded a valid satisfaction u/s. 153C as well. We thus follow the judicial consistency to affirm the CIT's identical lower appellate findings in the absence of any distinction on facts and circumstances involved herein. Revenue appeal dismissed.
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