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Change of Opinion Not 263: PCIT’s Roving Enquiry Direction Held Illegal
Case Law Details
- Case Name
- Safal Constructions (India) Pvt. Ltd. Vs PCIT (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Ahmedabad
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Safal Constructions (India) Pvt. Ltd. Vs PCIT (ITAT Ahmedabad)
Change of Opinion Not 263: PCIT’s Roving Enquiry Direction Held Illegal
Assessments for both years were completed u/s 153C on 30.09.2022 after mandatory approval u/s 153D. The AO had issued detailed notices u/s 142(1) (dated 12.02.2022 for AY 2018-19 and 10.02.2022 for AY 2019-20) and Assessee filed comprehensive replies (dated 07.03.2022 & 11.02.2022) containing page-wise rebuttal of every seized document recovered from the residence of one Shri Suresh Thakkar. AO, after verification, drew no adverse inference other than min...
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