ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, GUWAHATI vs. FORTUNE VANIJYA PRIVATE LIMITED, GUWAHATI
In the result both the appeal of the Revenue and the cross objections of the assessee stands partly allowed
ITA 21/GTY/2021[2011-12]Status: DisposedITAT Guwahati10 Dec 2021AY 2011-12
Bench: Shri P.M. Jagtap, Hon’Ble V.P (Kz) & Shri A. T. Varkey, Jm]
Section 132Section 132(4)Section 142(1)Section 153ASection 153CSection 68
69B of the Act, that the AO can validly initiate proceedings u/s 153C for such relevant assessment year. According to Shri Dudhwewala, when the Parliament has specified the jurisdictional fact for invoking jurisdiction u/s 153A/C of the Act for AY 2011-12 viz., the AO ought to have in his possession undisclosed assets of assessee qua the AY, then this
