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Assessment of Income of any other person - Section 153C

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..... able article or thing, seized or requisitioned, belongs to; or - (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdict .....

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..... oviso to section 153A(1) shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person. Exception of section 153C(1) - The Central Government may by rules made by it and published in the Official Gazette, specify the class or classes of cases in respect of such other p .....

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..... he previous year in which search is conducted under section 132 or requisition is made under section 132A and in respect of such assessment year- - ( a ) no return of income has been furnished by such other person and no notice under section 142(1) has been issued to him, or - ( b ) a return of income has been furnished by such other person but no notice under section 143(2) has been served and li .....

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..... issued, the Assessing Officer is required to arrive at a conclusive satisfaction that documents belong to a person other than searched person. The mere use of word 'satisfaction' in order or note, would not meet requirement of concept of satisfaction as used in section 153C . [Pepsi Foods (P.) Ltd. v ACIT 2015 (5) TMI 655 - DELHI HIGH COURT ] - Manuals - Ready reckoner - Law and practic .....

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