Sandhya Maulik Patel Vs ACIT (Gujarat High Court)
The present writ petitions arise from notices issued under Section 153C of the Income-tax Act, 1961 (“the Act”) dated 13 October 2021 by the Assessing Officer (AO) for Assessment Years (AY) 2014-15 to 2020-21. The petitions were filed in response to the issuance of these show-cause notices following a search conducted under Section 132 of the Act at the premises of a land broker and financer, Shri Dhaval Teli, Ahmedabad, on 15 October 2019. During the search, digital data and images from Shri Dhaval Teli’s mobile phone were acquired. Based on this data, the AO issued show-cause notices under Section 153C to the petitioners, who subsequently filed their income tax returns in October 2021 and requested copies of the satisfaction notes recorded by the AO. The petitioners received the satisfaction notes on 8 November 2021 and filed objections on 17 November 2021. Additional notices under Section 142(1) were issued on 9 July 2022, which were replied to on 20 July 2022. Further, a notice under Section 143(2) was issued on 20 January 2023, with the objections being disposed of on 23 January 2023. The AO later issued further notices under Section 142(1) on 18 February 2023 seeking detailed information regarding the alleged incriminating evidence.
