Shri Brijesh Kumar Verma vs. DCIT
Parties Involved
Facts Summary
The assessee, Shri Brijesh Kumar Verma, filed returns of income for AY 2016-17 and 2017-18. A search and seizure action was carried out on Jindal Bullion Ltd. Group (JBL) on 05.01.2017, and digital data from Hazir Johri software was seized. Based on this, proceedings u/s 153C of the Income Tax Act were initiated against the assessee. The Assessing Officer (AO) alleged unrecorded transactions between the assessee and JBL Group, leading to additions in the assessee's income. The assessee appealed against these additions, claiming that the transactions were recorded and that the seized material did not pertain to him.…
Decision in favour of
Assessee
Legal Issues
- 1. Initiation of proceedings u/s 153C of the Act
- 2. Time-bar of proceedings u/s 153C of the Act
- 3. Jurisdiction of AO to initiate proceedings u/s 153C of the Act
- 4. Validity of Assessment Order without DIN
- 5. Additions made without adequate opportunity and corroborative evidence
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
4 precedents cited in this judgement.
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