9911796707
TMI Blog2015 (8) TMI 982X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the assessment made under Section 143(1) of the Act for the AY 2009-10 was not valid, calls for no interference. No substantial question of law arises in the facts and circumstances of the present case. X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 143(3) by treating the AY 2009-10 as the year of search and reopened the assessments for the AYs 2003-04 to 2008-09. 3. The question raised before the ITAT was with reference to the first proviso to Section 153C (1). The ITAT has relied upon the judgment of this Court in SSP Aviation Ltd. v. Deputy Commissioner of Income Tax (2012) 252 CTR (Del) 291, which in para 14 held that while in the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ision in the case of DSL Properties Pvt. Ltd., which decision is pending consideration in ITA No. 585 of 2013 in this Court, in which a question of law has been framed, the decision in SSP Aviation Ltd. (supra) puts the matter beyond all doubt. In addition, the Court has been shown by learned counsel for the Respondent a circular dated 31st March 2014 issued by the CBDT, containing the guidelines ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ording/noting may be kept in the assessment folder of such other person. In case, the AO of the searched person exercises jurisdiction over the other person also, appropriate referencing should be made in the relevant assessment records of such other person. 5. It may be noted that in the present case satisfaction note was prepared by the AO on 25th February 2010. Consequently, the finding of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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