Sunita Goel v. Dy. CIT (2024)466 ITR 404 /162 taxmann.com 740 (Delhi)(HC)

S. 153C : Assessment-Income of any other person-Search-Opportunity of hearing was granted-Order is valid-Writ petition is dismissed.[Art. 226]

Dismissing the writ petition the Court held  that it was evident from the recitals of the notice dated March 4, 2021 and show-cause notice dated December 22, 2020 that the Assessing Officer had recorded his satisfaction before initiating the section 153C proceedings and furthermore, on April 19, 2021, the assessee had been duly provided with the satisfaction note. Furthermore, the assessee had chosen not to reply to the notice in the initial stage despite having been given ample opportunities of hearing and now after the passing of the assessment order under section 153C of the Act, the assessee was assailing it on the fulcrum of inordinate delay. The present was not a case where the principles of natural justice had not been met or the Assessing Officer had not duly applied his mind before passing the order.  Writ petition is dismissed.(AY.2014-15)