TMI Blog2023 (8) TMI 1181X X X X Extracts X X X X X X X X Extracts X X X X ..... al High Court in the case of CIT vs. RRJ Securities[ 2015 (11) TMI 19 - DELHI HIGH COURT] to give relief to the assessee and ld. DR could not bring anything to show how there was error in applying the law laid in (Supra). Also in Pr. Commissioner Of Income Tax v. Sarwar Agency Pvt. Ltd. [ 2017 (8) TMI 733 - DELHI HIGH COURT] Hon ble Delhi High Court has reaffirmed the law laid in RRJ Securities Case ( Supra) as held in the case of the 'other person' the AO issues notice only subsequent to the notices issued under Section 153 A to the searched person, the starting point for computation of the block period would be the date on which, based on the seized documents, notice is issued to the 'other person' under Section 153C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted in the assessment order itself. As a reply to the above-mentioned notice, the appellant filed his return of income on 14.07.2020. 3.2 Thereafter notice u/s 153C of the Act was issued by the assessing officer on 26.07.2021 to the appellant abating the proceedings u/s 148 of the Act and merging the erstwhile proceedings which were initiated u/s 148 of the Act. 3.3 Search was conducted on 05.01.2017 in the residential cum business premises of Sh. Kusharg Jindal promoter and Director of M/s. Jindal Bullion Ltd. During the course of search it was found that M/s. Faith Jewellers had no actual business activities and was providing only accommodation entries in the form of purchase bills on receipt of cash and the same amount was being tr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (P) Ltd. [2020]113 taxmann.com 601(SC) . 5. Revenue has come in appeal raising following grounds; i. Whether on the facts and circumstances of the case and in law, Ld. CIT(A) is correct in quashing the assessment order passed by the AO holding it to be barred by limitation without discussing on the merits of the case as the assessee used its unaccounted cash of Rs. 67,82,179/- to get accommodation entry from M/s Faith Jewellers. ii. Whether on the facts and circumstances of the case and in law, Ld. CIT(A) is correct in holding that assessment made for assessment year 2014-15 is invalid as 6 previous assessment years from the year of search has to be reckoned from the date when the books of accounts or seized documents were hand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he aforesaid, it becomes obvious that Ld. CIT(A) has merely taken into consideration the settled proposition of law of Jurisdictional High Court in the case of CIT vs. RRJ Securities (supra) to give relief to the assessee and ld. DR could not bring anything to show how there was error in applying the law laid in RRJ Securities Case (Supra). 6.1 Further, in Pr. Commissioner Of Income Tax v. Sarwar Agency Pvt. Ltd. 2017 ITR 397 400, Hon ble Delhi High Court has reaffirmed the law laid in RRJ Securities Case ( Supra) and declined to reconsider the same with following observations; 11. Mr. Ashok Manchanda, learned Senior Standing counsel for the Appellant, sought to pursue this Court to reconsider its view in RRJ Securities (sup ..... X X X X Extracts X X X X X X X X Extracts X X X X
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