Assessee can raise issue of jurisdiction U/s. 153C during appellate proceedings

ACIT Vs Smt. Pallavi Ravi (ITAT Bangalore)

Conclusion: Assessee was not precluded from raising the issue of jurisdiction under section 153C, merely because it did not object to the same during assessment proceedings and participating therein, as the issue was purely a legal issue and could be raised at any time in the course of appellate proceedings.

Held: A search operation under section 132 was conducted in the case of one Shri. H. B. Sudarshan. Conseque

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