TMI Blog2023 (12) TMI 294X X X X Extracts X X X X X X X X Extracts X X X X ..... the searched person, instead of the date of initiation of search on searched person and holding that AY 2011-12 to AY 2013-14 are outside the scope of section 153C? - HELD THAT:- We find that the first appellate authority has decided the appeal in favour of the assessee following the binding decision in the case of RRJ Securities Limited [ 2015 (11) TMI 19 - DELHI HIGH COURT] and subsequent amen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) has decided the captioned appeals by a consolidated order and since in the captioned appeals have common grounds, therefore, they are disposed of by this common order for the sake of convenience and brevity. 3. The common grievance of the revenue read as under :- 1. The Ld. CIT(A), Delhi has erred on facts and in law, on relying upon judgment of Hon'ble Delhi High Court dated 30.10.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ring the search on the relevant date. 3. The Ld. CIT(A), Delhi has erred on facts and in law, while not appreciating that the origin of action under Sections 153A and 153C lies in the same search action and thus, the assessment years should remain the same notwithstanding the date of handing over of material to the AO of the other person or date of initiation of proceedings under Section 153C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d dated 24.04.2023, wherein legal position on the issue has been settled by holding that for conducting assessments under sections 153A/153C of the Act, there must be incriminating evidence indicating undisclosed income discovered during the search, thus, block of six assessment years under sections 153A/153C can only be possible prior to date of search. 5. (a) The order of the Ld. Commission ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
