INCOME TAX APPELLATE TRIBUNAL (RANCHI BENCH)
SHRI PARTHA SARATHI CHAUDHURY, J
LAXMI HARD COKE MFG CO. DHANBAD – Appellant
Versus
ITO WARD 1(1) DHANBAD – Respondent
| Table of Content |
|---|
| 1. appeals preferred by the assessee (Para 1) |
| 2. assessment order should have been passed (Para 2) |
| 3. search had taken place (Para 3) |
| 4. entire basis for reopening (Para 4) |
| 5. appropriate procedure is section 153c (Para 5 , 6) |
ORDER
PER: PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER
1. Both these appeals preferred by the assessee emanate from the separate orders of National Faceless Appeal Centre, Delhi (NFAC)/learned Commissioner of Income Tax (Appeals) [in short, the ld. CIT(A)] both dated 24/03/2023 for the Assessment Year (AY) 2016-17 and 2018-19 respectively as per the grounds of appeal on record. Facts and circumstances of both these appeals are common. Grounds of appeal raised by the assessee in both these appeals are identical, therefore, with the consent of parties, both these appeals were clubbed and heard together and are being decided by this common order.
2. In these appeals, the assessee has preferred both the grounds on merit as well as legal ground. One of the legal ground that has been assailed in these appeals are that a search had taken place in a third party premises and certain incriminating materials were found there which pertains to the assessee which fo
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