TMI BlogMaintaining the Sanctity of Search and Seizure Procedures: Emphasizing the rigorous compliance with procedural requirements to uphold the legitimacy of search and seizure operationsX X X X Extracts X X X X X X X X Extracts X X X X ..... l dispute in question revolves around the interpretation and application of the provisions of the Income Tax Act, particularly Sections 132 , 143(3) , 153A, 153C , and 153D . This analysis will focus on the significant legal issues raised in the two cases, High Court and Supreme Court respectively. Case Overview The Pr. Commissioner of Income Tax Central Circle Anr. versus A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion under Section 132 . The ITAT quashed the assessments on the ground that there was no satisfaction note recorded by the assessing officer of the searched person, a crucial requirement under the Act. The Revenue contested this finding. Legal Issues: Validity of the ITAT's decision to quash the assessments based on the absence of a satisfaction note. Applicability of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dent: The Tribunal's decision was influenced by the Supreme Court's judgment in CIT vs. Calcutta Knitwears , which stressed the need for recording satisfaction by the AO in the case of the searched person. Period of Assessment under Sections 153A and 153C Issue: A critical point of contention is the relevant assessment year for the purpose of Sections 153A a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e parties not directly involved in the search (i.e., other persons under Section 153C ). Judicial Precedents: Decisions like CIT vs. Calcutta Knitwears and SSP Aviation Ltd. vs. DCIT [ 2014 (4) TMI 33 - SUPREME COURT] play a pivotal role in shaping the interpretation of these complex provisions. Conclusion This detailed examination of two significant cases illustrates the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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