ITA Nos.799 to 805/Chny/2024

Parties Involved

Facts Summary

The case involves appeals by M/s. Metal Impex against the Commissioner of Income Tax (Appeals)-18 for Assessment Years 2013-14, 2014-15, 2016-17 to 2020-21. The appeals challenge the reopening of assessments and the additions made by the Assessing Officer (AO). The AO had issued notices under Section 153C of the Income Tax Act, 1961, for the assessment years in question. The assessee argued that the AO did not have the necessary jurisdictional facts to issue the notices and that the additions were not based on any incriminating material found during the search. The AO had relied on seized documents from a search conducted on a third party, which the assessee argued did not pertain to them.…

Legal Issues

• 1. Whether the AO had validly assumed jurisdiction to issue notice u/s 153C of the Act for AY 2013-14.
• 2. Whether the seized material pertained to the assessee.

Judgment Outcome

Decided in favour of Assessee.

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