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Bajrang Engineers Private Limited, ... vs Acit,Central Circle, Sambalpur on 7 June, 2022

14. Careful perusal of the language employed in section 153C makes it clear that in so far as a third party is concerned, the Legislature has not provided for making the assessments for all six years, in other words, based upon seized material the Assessing Officer has to record his satisfaction that the books of account/documents seized or requisitioned have a bearing on determination of total income of such other person for the relevant assessment year. Further similar view has also been taken by the Tribunal in Trishul Hi-tech Industries Vs. Dy.CIT (in IT(SS) Nos.82,84-86/Kol/2011 dated 24.9.2014), where the years involved were A.Ys.200405 to 2006-07, explaining the amendment to section 153C by Finance (No.2) Act, 2014 to be clarificatory and thus, retrospective.
Income Tax Appellate Tribunal - Cuttack Cites 19 - Cited by 1 - Full Document

Principal Commissioner Of Income-Tax, ... vs R. M. Investment And Trading Co. Pvt. Ltd on 28 January, 2019

14. Careful perusal of the language employed in section 153C makes it clear that in so far as a third party is concerned, the Legislature has not provided for making the assessments for all six years, in other words, based upon seized material the Assessing Officer has to record his satisfaction that the books of account/documents seized or requisitioned have a bearing on determination of total income of such other person for the relevant assessment year, Further, similar view has also been taken by the Tribunal in Trishul Hi-tech Industries Vs. Dy. CIT (in IT (SS) Nos. 82, 84-86/Kol/2011 dated 24.9.2014). where the years involved were A.Y.s 2004-05 to 2006-97, explaining the amendment to section 153C by Finance (No.2) Act, 2014 to be clarificatory and thus, retrospective.
Bombay High Court Cites 5 - Cited by 1 - S K Shinde - Full Document

Principal Commissioner Of Income-Tax, ... vs M/S. R.M. Investment And Trading ... on 28 January, 2019

14. Careful perusal of the language employed in section 153C makes it clear that in so far as a third party is concerned, the Legislature has not provided for making the assessments for all six years, in other words, based upon seized material the Assessing Officer has to record his satisfaction that the books of account/documents seized or requisitioned have a bearing on determination of total income of such other person for the relevant assessment year, Further, similar view has also been taken by the Tribunal in Trishul Hi-tech Industries Vs. Dy. CIT (in IT (SS) Nos. 82, 84-86/Kol/2011 dated 24.9.2014). where the years involved were A.Y.s 2004-05 to 2006-97, explaining the amendment to section 153C by Finance (No.2) Act, 2014 to be clarificatory and thus, retrospective.
Bombay High Court Cites 5 - Cited by 0 - S K Shinde - Full Document

Principal Commissioner Of Income Tax ... vs R M. Investment And Trading Co. Pvt Ltd on 28 January, 2019

14. Careful perusal of the language employed in section 153C makes it clear that in so far as a third party is concerned, the Legislature has not provided for making the assessments for all six years, in other words, based upon seized material the Assessing Officer has to record his satisfaction that the books of account/documents seized or requisitioned have a bearing on determination of total income of such other person for the relevant assessment year, Further, similar view has also been taken by the Tribunal in Trishul Hi-tech Industries Vs. Dy. CIT (in IT (SS) Nos. 82, 84-86/Kol/2011 dated 24.9.2014). where the years involved were A.Y.s 2004-05 to 2006-97, explaining the amendment to section 153C by Finance (No.2) Act, 2014 to be clarificatory and thus, retrospective.
Bombay High Court Cites 5 - Cited by 0 - S K Shinde - Full Document

Principal Commissioner Of Income-Tax, ... vs M/S. R. M. Investment And Trading Co. ... on 28 January, 2019

14. Careful perusal of the language employed in section 153C makes it clear that in so far as a third party is concerned, the Legislature has not provided for making the assessments for all six years, in other words, based upon seized material the Assessing Officer has to record his satisfaction that the books of account/documents seized or requisitioned have a bearing on determination of total income of such other person for the relevant assessment year, Further, similar view has also been taken by the Tribunal in Trishul Hi-tech Industries Vs. Dy. CIT (in IT (SS) Nos. 82, 84-86/Kol/2011 dated 24.9.2014). where the years involved were A.Y.s 2004-05 to 2006-97, explaining the amendment to section 153C by Finance (No.2) Act, 2014 to be clarificatory and thus, retrospective.
Bombay High Court Cites 5 - Cited by 0 - S K Shinde - Full Document
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