Rajan Jewellery. v. CIT (2019) 414 ITR 621 /177 DTR 369/308 CTR 602/ 266 Taxman 357 (Ker.)(HC)

S. 132 : Search and seizure–Validity-Objection that panchas were not present at the time of search- Cannot be raised for first time. before CIT(A) after a period of three years . [S. 153A]

On appeal the High Court held that, the question of presence of panchas raised for the first time before the first appellate authority after a period of three years from the search is conducted, cannot at all be countenanced .  Appeal of the assessee is dismissed.( AY. 2003 -04 to 2009 10)