2025 (5) TMI 1719

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....: Mr Somil Agarwal and Mr Dushyant Agrawal, Advocates. For the Respondents Through: Mr Siddhartha Sinha, Advocate. VIBHU BAKHRU, J. (ORAL) 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 28.08.2024 [the impugned notice] issued under 153C of the Income Tax Act, 1961 [the Act] as well as the proceedings for re-assessment of the petitioner's income in respect....

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.... 4. In so far as the petitioner is concerned, information allegedly found was regarding a purported transaction of Rs. 70,78,680/-, which was allegedly supported by bogus invoice. However, the said transaction pertains to the Financial Year 2014-15. Paragraph 13 of the satisfaction note is set out below: "13. Further, during the search action, several digital devices were cloned and had been an....

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....ove that the information provided in the satisfaction note dated 28.08.2024 entered by the AO of the assessee could not possibly lead to the conclusion that the income of the Assessee for AY 2019-20 had escaped assessment. The pen drive found cannot be considered as containing any incriminating material pertaining to the petitioner in respect of AY 2019-20. Thus, the petitioner's assessment for th....