SUSHIL KUMAR KANODIA,PATNA vs. ACIT, CENTRAL CIRCLE-2, PATNA
In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed
ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18
Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025
For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C
b) of section 153C(1) of the Act. The ld
AR submitted that the case of the assessee finds support from the decision of Bhawna Garg vs DCIT Central, reported in [2025] 180
taxmann.com 9 (Delhi - Trib.), wherein it has been held that when the satisfaction note was recorded in the next financial year of the search and seizure operation
