Orders u/s 263 could be passed only after taking into consideration explanation offered by the Assessee

Facts of the Case

A search and seizure operation u/s 132 of the I.T. Act 1961 was carried out During the course of search, certain documents were found and seized relating to the assessee. Accordingly notice u/s 153C was issued. Assessee executed the development agreement for developing a piece of land for which there was no endorsement of registration authorities on the reverse of the Development Agreement cum GPA which indicate that the agreement was not registered in the absence of which the complian

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