DCIT CEN CIR 2(2), MUMBAI vs. INFINITY INDUSTRIES P. LTD, MUMBAI
In the result, appeal of the assessee for A
ITA 2933/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 Dec 2022AY 2010-11
Section 144Section 145(3)
…see in its normal course of business cannot fall under the ambit of incriminating material found during the course of search. Our view is further fortified by the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Param Diary Limited reported in 439 ITR 89 wherein it was held that regular books of accounts of the assessee, by no stretch of imagination, could be treated as incriminating material to form basis of framing assessment u/s.143(3) r.w.s. 153A of the Act. In any case, we find that the original M/s. Infinity Industries Pvt. Ltd. return of income for the A.Y.2007-08 was filed by the assessee…