Initiation of proceedings u/s 153C based on documents impounded during survey u/s 133A is bad in law

Sai Shraddha Enterprises Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that initiation of proceedings under section 153C of the Income Tax Act based on documents impounded during the course of survey under section 133A of the Income Tax Act is bad in law and unjustified as no such material were found during the course of search.

Facts- A search was carried out u/s. 132 of the Act and survey u/s. 133A of the Act was also carried out on 31st July, 2014 in Ameya Group of cases. The

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