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2025 Supreme(Online)(Del) 48697

Carol Infrastructure Private Limited v. Assistant Commissioner Of Income Tax Central Circle 27 Delhi & Anr.


VIBHU BAKHRU, J. (ORAL)

1. The Petitioner [the Assessee] has filed the present petition, inter alia, impugning the proceedings initiated pursuant to the notice dated 19.12.2023 [impugned notice] issued under Section 153C of the Income Tax Act, 1961 [the Act] in respect of Assessment Year [AY] 2015-16.

2. The Assessee had filed the return of income for the relevant AY 2015-16, on 30.09.2015, declaring a total income of ₹32,61,010/-. On 18.10.2019, search and seizure operation were conducted under Section 132 of the Act in respect of persons belonging to the Alankit Group. Thereafter, on 19.12.2023, the notice under Section 153C of the Act was issued which is

impugned in present petition.

3. The Assessing Officer [AO] of the searched person had recorded a satisfaction note dated 24.06.2022 [the satisfaction note] to the effect that he was satisfied that the documents belonging or containing information relating to the assessee, were found during the course of search. The satisfaction note also records that the documents in question were handed over to the AO exercising jurisdiction in the case of the assessee.

4. It is the Petitioner’s case that no proceedings under Section 153C can be co

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