JUDGMENT

BADAR DURREZ AHMED, J. (ORAL)

1. These six (6) writ petitions raise a common issue and therefore the same are being decided together. The relevant Assessment Years are 2006-2007 to 2011-2012. By way of these writ petitions the petitioner (PepsiCo India Holdings Private Limited) has sought the quashing of the notices issued on 02.08.2013 under Section 153C of the Income Tax Act, 1961 (hereinafter referred to as the „said Act‟).

2. A search and seizure operation under Section 132(1) of the said Act was conducted on 27.03.2012 on the Jaipuria Group. It is the case of the Revenue that during the said operation certain documents “belonging” to the petitioner were found. Consequently, the Assessing Officer of the Jaipuria Group prepared a Satisfaction Note dated 29.07.2013 to the effect that the documents mentioned therein belonged to the petitioner. It is thereafter that the Satisfaction Note as well as the said documents were symbolically handed over to the Assessing Officer of the petitioner. We use the expression “symbolically handed over” because of the fact that the Assessing Officer of the Jaipuria Group and the Assessing of the petitioner was one and the same person. It is