TMI Blog2015 (12) TMI 1653X X X X Extracts X X X X X X X X Extracts X X X X ..... . Therefore, the appeals against the order of the CIT(A) confirming the order of the A.O. under section 154 are also quashed as having no basis. - ITA. No. 1082, 1083, 1084, 1085, 1085, 1086, 1087, 1090, 1091, 1211, 1212, 1213, 1214, 1215, 1216, 1217, 1218/H/2014 - - - Dated:- 9-12-2015 - P. Madhavi Devi (Judicial Member) And S. Rifaur Rahman (Accountant Member) For the Assessee : P. Muralimohan Rao For the Revenue : B. Kurmi Naidu ORDER All are appeals of the respective assessees for the A.Y. 2006-07. The assessees are in appeal before us against the order of the Ld. CIT(A) in confirming the disallowances and the consequential additions made by the A.O. under section 143(3) read with section 153C of the I.T. Act and a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . As seen in the case of Smt. Reena Peterson, the order sheet entry is as follows : Mrs. Reena Peterson, PAN APOPP0610C w/o. Peterson Asst. Year 2006-07 #14/240, Mirjalguda Malkajgiri Hyderabad. Search Seizure operations were conducted in the MBS Jewellers Pvt. Ltd., group of cases on 11.03.2010. During the course of search, books of accounts, documents other loose sheets were found and seized. As per the seized documents, pages 03 to 09 of Annexure A/PCG/Res/01 relates to Mrs. Reena Peterson w/o. R. Peterson proceedings u/s.153C is initiated. Put up Notices u/s.153C 142(1) of the IT Act. 3. Similar order sheet entries are also made in the case of oth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -3-2010. During the course of search operation documents belonging to the assessee have been seized. Hence, it is considered to initiate proceeding under section 153C. [Para 6J The aforesaid section mandates recording of satisfaction of the Assessing Officer(s) is a precondition for invoking jurisdiction and it is not a mere formality because recording of satisfaction postulates application of mind consciously as the documents seized must be belonging to the any other person other than the person referred to in section 153A. It was contended that the same Assessing Officer was involved in the matter. This fact does not dispense with above requirement. It is settled position of law that when a thing is to be done in one particular ..... X X X X Extracts X X X X X X X X Extracts X X X X
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