Assessee is an individual and regular in filling his return of income. Assessee has received the Notice U\/Sec.153C for A.Y. 2019-20 and preceding 6 years on the basis of noting on the seized papers found during the course of search with the Developer from whom assessee has purchased the flat and statement given by the CFO of the developer U\/SEc.132(4) of the Act that noting on seized paper is cash component in the transaction of purchase of flat\u00a0 and assessee has also accepted that\u00a0 said amount as on Money in the application made before the settlement commission and therefore the AO of the assessee has drawn the inference that that there is undisclosed income in the hands of the assessee and accordingly the satisfaction U\/Sec. 153C has been recorded for initiating the proceedings for A.Y. 2019-20 and 6 years prior to A.Y. 2019-20.<\/p>\n
The seized paper do not give any date or reference of project where flat purchase by the assessee or any signature of the assessee,\u00a0 even the name mentioned on the seized paper is not the full name of the assessee.<\/p>\n
Issues :<\/p>\n
1.whether action of the AO for issuance of Notice U\/Sec.153C for A.Y. 2019-20 and 6 years prior to A.Y. 2019-20 is valid?<\/p>\n
2. The ground taken by the AO about acceptance of CFO in statement U\/SEc. 132(4) and acceptance of on money as per noting by the assessee before Settlement Commission is sacrosanct and\u00a0 drawing the inference about the assessee must have paid on Money is correct?<\/p>\n
3. what is remedy available to the assessee?<\/p>\n
pl guide<\/p>\n","protected":false},"comment_status":"open","ping_status":"closed","template":"","qa_expert":[1021,1022],"qa_category":[23],"qa_tag":[1025,156,202],"class_list":["post-35378","qa","type-qa","status-publish","hentry","qa_expert-ksa-legal-chambers","qa_expert-reserch-team","qa_category-income-tax","qa_tag-assessment-of-any-other-person","qa_tag-search","qa_tag-search-assessment"],"acf":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa\/35378","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/qa"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=35378"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=35378"}],"wp:term":[{"taxonomy":"qa_expert","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa_expert?post=35378"},{"taxonomy":"qa_category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa_category?post=35378"},{"taxonomy":"qa_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/qa_tag?post=35378"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}