TMI Blog2014 (4) TMI 1109X X X X Extracts X X X X X X X X Extracts X X X X ..... the person who was searched which is a condition precedent. Settled position of law has been applied. - Decided in favour of assessee - I.T.T.A. No. 254 of 2014 - - - Dated:- 15-4-2014 - SRI KALYAN JYOTI SENGUPTA AND SRI SANJAY KUMAR JJ. For the Appellant: Narasimha Sarma JUDGMENT: (per Hon ble the Chief Justice Sri Kalyan Jyoti Sengupta ) This appeal is sought to be prefer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sfaction ? (iii) In the facts and circumstances of the case, whether the ITAT is correct in law in taking cognizance of the version that the respondentassessee filed returns in the status of HUF voluntarily for the assessment years 2000-2001 to 2006-2007 on 29-12-2006, ignoring the fact that the returns were filed subsequent to the search? (iv) In the facts and circumstances of the case, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of conditions laid down in Section 153C of the Income Tax Act, 1961, as there is no recording of satisfaction by the Assessing Officer that undisclosed income belongs to any person other than the person who was searched which is a condition precedent. Settled position of law has been applied. Therefore, we do not find any reason to interfere with the judgment and order of the learned Tribunal. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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