DCIT, New Delhi vs. Sh. Sanjay Jain, New Delhi
In the result, appeals of the department are dismissed and the Cross Objections of the assessee’s are allowed as indicated above
ITA 5325/DEL/2013[2005-06]Status: DisposedITAT Delhi06 Oct 2015AY 2005-06
Bench: Sh. N. K. Saini, Am & Sh. A. T. Varkey, Jm
Section 132Section 153A
…consequence for the purpose of computing the limitation period u/s 153B. However an interesting question arose about the scope of the expression "last of the authorizations" mentioned in Section 158BE before the Tribunal in the case of Shah Rukh Khan Vs. ACIT 104 ITD 221 (Mum). In that case, one authorization was issued in respect of residence on 17/12/96 while two authorizations were issued on 23/12/96 in respect of two lockers. In respect of search of lockers, panchnamas were prepared on the same date. However, the authorization dated 17/12/96 was issued on three dates i.e. 17/12/96, 23/12/96 and 30/1/97, the c…