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Delhi High Court held that as AO didn’t assume jurisdiction under section 153C of the Income Tax Act, recourse to section 147 of the Income Tax Act for reassessment proceedings justified. Accordingly, appeal by revenue allowed.
Delhi High Court held that non-satisfaction of conditions for reopening assessment u/s. 153C of the Income Tax Act doesn’t prohibit AO from taking recourse u/s. 147. Thus, reopening u/s. 147 based on information from investigation wing justified.
The AO proceeded to treat the transactions as penny stock and relying on the investigation report on penny stock from the Investigation Wing, he disallowed the same u/s 68 of the Act to the extent of Rs.1,28,58,450/-.
The present appeal is preferred by the revenue. The only issue in this appeal of the Revenue is against the order of CIT(A) deleting addition made by the AO towards unexplained expenditure u/s.69C of the Act in respect of trade payable settled outside books of accounts.
The assessee filed three appeals against order of CIT(A) for A.Y. 2010-11, 2012-13 and 2013-14. It is important to note that inspite of putting up the case of hearing several times, no one appeared on behalf of the assessee.
A search and seizure operation u/s 132 of the Income-tax Act, 1961 was conducted on 23.07.2015 and subsequent dates in different business and residential premises of Deepak Agarwal, Mukesh Kumar and others, group of cases based at Delhi.
Based on this satisfaction, a separate satisfaction note stood recorded u/s 153C of the Act in the hands of the assessee on 3.10.2022 by AO of the assessee. Hence the date of search in the case of the assessee becomes 3.10.2022 relevant to Asst Year 2023-24.
Aggrieved by the relief granted by CIT(A) to assessee, Revenue preferred Appeal before ITAT for the assessment years under consideration and against the deletion of additions made by AO. ITAT dismissed the appeal.
Delhi High Court remands ITAT case for reconsideration on S. 153C, clarifying its applicability to searches conducted before the Finance Act 2015 amendment.
As per provisions of section 153C of the Act, notice required to be issued to the other person would be a notice under section 153C of the Act, but even then assessment is to be framed in accordance with the procedure prescribed under section 153A of the Act.
