M/S. DEEPAK PURSHOTTAM SHAH (HUF) Vs. ACIT, CENTRAL CIRCLE -2
Parties Involved
Facts Summary
A search action under section 132 was carried out in the case of Swastik Group on 31/07/2014. The assessee, a partner in various concerns of the said group, filed its return of income for A.Y.2009-10 on 21/12/2010 declaring total income of Rs.85,36,940/-. Following the search, proceedings under section 153C were initiated, and an assessment was completed with various additions. The assessee appealed against the order passed by the Commissioner of Income Tax (Appeals) on 15/09/2025. The assessee argued that the assessment was completed without valid jurisdiction as no specific satisfaction note was recorded for A.Y.2009-10 by the Assessing Officer. The assessee also challenged the addition of Rs.14,80,00,000/- as undisclosed income in the form of profit from the sale of land to Tata Housing Development Co. Limited.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the satisfaction recorded under section 153C discloses any incriminating material having nexus with the assessment year under consideration, i.e., A.Y.2009-10.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
7 precedents cited in this judgement.
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