TMI Blog2015 (8) TMI 982X X X X Extracts X X X X X X X X Extracts X X X X ..... no interference. No substantial question of law arises in the facts and circumstances of the present case. - ITA No. 337/2015 - - - Dated:- 11-8-2015 - Dr. S. Muralidhar And Vibhu Bakhru, JJ. For the Appellant : Ms Suruchi Aggarwal, Senior Standing Counsel with Ms Lakshami Gurung, Junior Standing counsel For the Respondents : Mr Kapil Goel, Adv. with Mr Ankit Gupta, Advs. ORDER ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as the year of search and reopened the assessments for the AYs 2003-04 to 2008-09. 3. The question raised before the ITAT was with reference to the first proviso to Section 153C (1). The ITAT has relied upon the judgment of this Court in SSP Aviation Ltd. v. Deputy Commissioner of Income Tax (2012) 252 CTR (Del) 291, which in para 14 held that while in the case of the searched person, the date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d., which decision is pending consideration in ITA No. 585 of 2013 in this Court, in which a question of law has been framed, the decision in SSP Aviation Ltd. (supra) puts the matter beyond all doubt. In addition, the Court has been shown by learned counsel for the Respondent a circular dated 31st March 2014 issued by the CBDT, containing the guidelines regarding Section 153C of the Act. Para 2.5 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lder of such other person. In case, the AO of the searched person exercises jurisdiction over the other person also, appropriate referencing should be made in the relevant assessment records of such other person. 5. It may be noted that in the present case satisfaction note was prepared by the AO on 25th February 2010. Consequently, the finding of the ITAT in the present case that the assessme ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
