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1 - 10 of 63 (0.67 seconds)Section 153A in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Section 234A in The Income Tax Act, 1961 [Entire Act]
Section 234B in The Income Tax Act, 1961 [Entire Act]
Section 132 in The Income Tax Act, 1961 [Entire Act]
Acit vs M/S. Serajuddin & Co. Kolkata on 15 March, 2023
39. With regard to the decision rendered by the Hon'ble Orissa High Court in
the case of ACIT vs. Serajuddin & Co. (supra), while the same is not rendered by the
jurisdictional High Court, it has been raised by the assessee and therefore, must be
considered by us while rendering our decision. In consideration thereof, we cannot
help but notice that the Hon'ble Orissa High Court has based its findings on the
search manual guidelines laid down by the CBDT for block assessments under
Chapter XIV-B and the CBDT has issued a separate set of guidelines for search
assessments to be done under Chapter XIV. Therefore, even while the provisions of
section 158BG may be para materia to the provisions of section 153D, the
guidelines laid down by the CBDT in respect of conduct of assessments under
sections 153A to 153D are completely different. In those circumstances, the
guidelines laid down for search assessments under Chapter XIV that have been
brought to our knowledge by the ld. DRs through the third supplementary paper
book filed on 22.10.2024 would be the parameter under which these particular
assessments must be judged.