Assessee subjected to search, cannot be placed on a different pedestal than assessee who is not subjected to search

Facts of the Case/Proceedings before AO

1. The assessment for AY 2011-12 completed on 30-03- 2015, did not abate consequent to the second search. The AO thereafter initiated proceedings u/s 153A for AY 2011-12 on 05-11-2016 and notices u/s 143(2) & 142(1) of the Act were issued calling for details/information.

2. The AO relied on statements of third parties and observed that the share capital of Rs.35.50 crores raised by the assessee in the earlier year/s and its

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