CM Nos.26463, 26464 & 26466/2016 (for exemption)

1. Allowed, subject to all just exceptions.

2. The applications are disposed off.

ITA Nos. 449-451 & 453 of 2016

3. Admit.

4. The question of law urged is whether in the circumstances of the case, the ITAT findings that the satisfaction note was flawed and could not withstand scrutiny under Section 153(C) of the Income Tax Act, 1961 (hereinafter to be referred as ‘the Act’) is correct.

5. This Court does not propose to advert the facts in detail except to state that the search and seizure operation was carried out in the premises of Shri Tejwant Singh and one Shri Ved Prakash Bharti. A survey too was conducted under Section 133A of the Act in the premises of the assessee. As a consequence of that, notice was issued to the assessee under Section 153C of the Act by the Assessing Officer (AO), who also co-incidentally happened to be the AO of the searched party i.e Tejwant Singh and Ved Prakash Bharti and had issued notice under Section 153A of the Act. The assessments and additions finally made in the block period were the subje