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2019 Supreme(SC) 220

A.M.SAPRE, DINESH MAHESHWARI
Commissioner of Income Tax-I – Appellant
Versus
Rashtradoot (HUF) – Respondent


Advocates Appeared:
For the Appellant :Mrs. Anil Katiyar, Advocate
For the Respondent:Mr. Bhargava V. Desai, Advocate.

JUDGMENT

Abhay Manohar Sapre, J.

1. Leave granted.

2. This appeal is filed against the final judgment and order dated 25.10.2016 passed by the High Court of Judicature for Rajasthan, Bench at Jaipur in D.B. Income Tax Appeal No. 43 of 2002 whereby the Division Bench of the High Court dismissed the appeal filed by the appellant herein and affirmed the order dated 24.05.2001 passed by the Income Tax Appellate Tribunal (ITAT), Jaipur Bench, Jaipur in I.T.S.S.A. No.29/JP/2000.

3. A few facts need mention infra for the disposal of the appeal.

4. This appeal filed by the Revenue arises out of the income tax proceedings initiated against the respondent(assessee) on the basis of a search operation which was carried out by the Income Tax Department in assessee’s premises on 04.09.1997. This gave rise to initiation of assessment proceedings for the block period from 01.04.1987 to 04.09.1997 (Assessment Years 1987-88 to 1996-97 and 1997-98 up to 04.09.1997) against the assessee to determine their tax liability as a result of search operations carried in their premises. The matter, out of the block assessment proceedings, reached to the Income Tax Appellate Tribunal at the instance of the respon



















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