2015 (7) TMI 1101 - HC - Income Tax

Notice u/s 153C Search and seizure u/s 132(1) Satisfaction note - Held that - Matter stands covered against the Revenue by virtue of the judgment of this Court in Pepsi India Holdings P. Ltd. v. ACIT (2014 (8) TMI 898 - DELHI HIGH COURT) wherein held Tthe finding of photocopies in the possession of a searched person does not necessarily mean and imply that they belong to the person who holds the originals - Possession of documents and possession of photocopies of documents are two separate things. The finding of photocopies in the possession of a searched person does not necessarily mean and imply that they belong to the person who holds the originals - Possession of documents and possession of photocopies of documents are two separate things - the ingredients of Section 153C of the Act have not been satisfied - thus the notice issued u/s 153C is set aside Decided in favour of Assessee.

Summary

The Delhi High Court dismissed the appeal as the matter was covered by a previous judgment in Pepsi India Holdings P. Ltd. v. ACIT (2014) 50 Taxmann.com 299 (Delhi).