COURT: | Delhi High Court |
CORAM: | Badar Durrez Ahmed J, Najmi Waziri J |
SECTION(S): | 153A, 153C |
GENRE: | Domestic Tax |
CATCH WORDS: | Search assessment |
COUNSEL: | Deepak Chopra, Rashi Khanna |
DATE: | August 14, 2014 (Date of pronouncement) |
DATE: | December 1, 2014 (Date of publication) |
AY: | 2006-07 to 2011-12 |
FILE: | Click here to view full post with file download link |
CITATION: | |
S. 153C cannot be invoked unless the AO is satisfied for cogent reasons that the seized documents do not belong to the searched person. Finding of photocopies with the searched person does not mean they "belong" to the person holding the originals. The distinction between "belongs to" and "relates to" or "refers to" must be borne in mind by the AO |
(i) First of all, it is nobody’s case that the Jaipuria Group had disclaimed these documents as belonging to them. Unless and until it is established that the documents do not belong to the searched person, the provisions of Section …
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