Judgement

I want to have judgement of Justice Siddhartha Nautiyal, Ahmedabad ITAT Bench on 143(1) and 80P of the I T Act

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  MA filed after decision of SC in the context of 153C

Assessee has challenged  validity of the impugned section 153C proceedings for want of a proper satisfaction.   Assessing Officer appears to have initiated the impugned section 153C proceedings  in light of his satisfaction note prepared on 13.01.2016 that the corresponding seized material in fact “pertains to” the assessee  during the course of search with xyz and thus had a “bearing” on its undisclosed income. ITAT has passed the order in favour of the assessee by relying upon the   decision in Income Tax Appeal No.83/2014 CIT vs. M/s. Arpit Land Pvt. Ltd., dated 07.02.2017 has decided the very issue of validity of…

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