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2021 (6) TMI 229

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..... ax returns filed for the relevant AYs, and therefore, the said exercise was carried out. We are of the view that the first step that the concerned officer needs to take to expedite the proceedings is, to submit the appraisal report concerning the search to the petitioner s AO. Therefore, while we are issuing notice in the captioned application, the concerned officer is also directed to submit the appraisal report to the petitioner s AO within the next ten days. Revenue will also get the 7 properties, referred to hereinabove (apart from the 10 properties which are reflected in the subject title deeds), valued, so that one has an idea as to what is the security available to the respondents/revenue. Accordingly, issue notice. Mr. Hos .....

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..... or AY 2020-2021. It is also Mr. Gulati s submission that, in any event, vide communication dated 09.03.2021, audited books of accounts were submitted to the concerned officer. To be noted, the search was carried out on 26.10.2020. 2.2. It is Mr. Gulati s contention that, even if, for the moment, it is assumed that the cash component concerning these 10 properties was not disclosed; that aspect would become, if at all, the subject matter of the assessment proceedings, and therefore, if found credible, the assessing officer (in short AO ) could then add the same to the petitioner s declared income by taking recourse to either Section 69 or Section 28 of the Income Tax, Act, 1961 (in short the Act ). 2.3. In other words, in effect, it .....

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..... eport is submitted within the next one week, then the petitioner will have time to respond to the queries that the AO may have with regard to the proposed additions, if any. 2.7. We may also take note of the submission made by Mr. Gulati that, the purported cash component, to which a reference is made in the order dated 01.05.2021, pertains to another assessee, i.e., Girdhari Lal Constructions Pvt. Ltd. 2.8 Mr. Zoheb Hossain, who appears for the respondents/revenue, says that via the order dated 19.04.2021, the Court directed the concerned officer to ascertain, as to whether the aforementioned 10 properties were disclosed in the income tax returns filed for the relevant AYs, and therefore, the said exercise was carried out. 3. Havi .....

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