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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI SHAMIM YAHYA, A.M, SHRI KUL BHARAT, J.M
Revenue – Appellant
Versus
Mr. Yogesh Gambhir – Respondent
| Table of Content |
|---|
| 1. this appeal by the revenue is directed against order of ld. cit(a). (Para 1 , 2) |
| 2. cit(a) granted relief to the assessee, establishing the need for assessment under section 153c. (Para 3 , 4) |
| 3. the assessment framed was found to be based on incorrect provisions, confirming the cit(a)'s finding. (Para 5) |
| 4. court heard both parties' arguments regarding the correct sections applicable. (Para 6 , 7) |
| 5. the appeal of the revenue is dismissed, upholding the cit(a)'s order. (Para 8) |
ORDER
PER SHAMIM YAHYA (A.M):
This appeal by the Revenue is directed against order of ld. CIT(A) dated 02.08.2023 and pertains to A.Y. 2017-18.
2. Grounds of appeals read as under:-
Whether on the facts and circumstances of the case Ld. CIT(A) has erred in differentiating the information concluded on the basis of seized material(as required u/s 148 of the Act) as per section 153C of the Act.
Whether on the facts and circumstances of the case Ld. CIT(A) has erred in considering the fact that satisfaction note by AO of the searched person is a necessary requirement for proceedings u/s 153C of the Act.
Whether in facts and circumstances of the case, Ld. CIT(A) has erred in overlooking the fact that no
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