Wachovia Marketing Pvt. Ltd., Delhi vs. ITO, Ward-27(2), New Delhi
In the result, the appeal of assessee is dismissed
ITA 847/DEL/2020[2011-12]Status: DisposedITAT Delhi31 Aug 2022AY 2011-12
Bench: Shri Anil Chaturvedi
For Appellant: Shri Piyush Kaushik, AdvFor Respondent: Shri Om Prakash, Sr. D.R
Section 132Section 132(4)Section 142(1)Section 143(3)Section 147Section 148Section 68
…proceedings u/s 147 of the Act and the AO had recorded satisfaction as contemplated u/s 153C of the Act. 16. I also find that Hon’ble Madras High Court in the case of Karti P. Chidambaram V. Principal Director of Income- Tax (Investigation) and others [2021] 436 ITR 340 (Mad) has held that there is distinction between the provisions of Section 147, 153A and 153C of the Act and has held that only after handing over of the materials to the Assessing Officer of the other person, he is empowered to issue notice under section 153C of the Act and not otherwise. The relevant observations of the High Court reads as unde…