PADAM KUMAR JAIN,RANCHI vs. DCIT, CENTRAL CIRCLE-1, RANCHI

In the result, all the appeals filed by the assessee are allowed and copy of common order passed is to be placed on respective case files

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

11. We have given a careful consideration to the rival submissions and perused the materials available on record. We note that from the plain reading of the above deeming fiction inserted by way of explanation 5A to section 271(1)(c) of the Act, it is abundantly clear that all the searches initiated under section