M/s. Cindrella Polymers Pvt. Ltd. Vs. DCIT

Parties Involved

Facts Summary

The assessee/appellant has raised its first and foremost legal ground/argument challenging both the impugned section 153C r.w.s. 143(3) assessments framed by the learned Assessing Officer and upheld in the lower appellate discussion(s). The learned departmental authorities had carried out a search in issue in M/s. Alankit Group on 18.10.2019 wherein it is alleged to have come across the corresponding incriminating material against the assessee as well. The assessee's jurisdictional Assessing Officer recorded his section 153C common satisfaction in its case relating to assessment years 2015-16 and 2016-17. However, the Assessing Officer did not make it clear that the alleged incriminating material sought to be proceeded against the assessee had a 'bearing' on the determination of its total income in these assessment years.…

Legal Issues

• 1. Whether the Assessing Officer was required to specifically incorporate the word 'bearing' on the determination of the assessee's taxable income in the satisfaction note under section 153C of the Act.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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