COMMISSIONER OF INCOME TAX Vs. JASJIT SINGH

JUDGEMENT

(1.) Delay condoned in SLP(C) Dy. No. 30718 of 2023 and all connected petitions.

(2.) Special leave granted. With the consent of the learned counsel for the parties, the appeals were heard.

(3.) In this batch of appeals the revenue questions four sets of orders of the Delhi High Court, dismissing its appeals under Sec. 260A of the Income Tax Act, 1961 (hereinafter referred to as IT Act). Though the facts in each appeal differ, substantially for the purposes of clarity and completeness the facts in the appeal arising from SLP (C) No.6644 of 2016 are taken into account. The facts are that search and seizure proceedings were conducted in the premises of one M/s KOUTON Group on 19/2/2009. In the course of scrutiny, the concerned Assessing Officer (A.O.) having jurisdiction after issuing notice under Sec. 154 A of the IT Act, to the searched party, was of the opinion that some documents and material "belonging to" the respondents(s) assessee, were involved. Therefore, notices were issued to them by the AO having jurisdiction over their assessments on different dates (i.e. 25/2/2010 in [SLP(C) No. 6644 of 2016 and SLP(C)No. 14447 of 2016], 12/3/2009 in [SLP(C)No. 23621 of 2016] and 11/8/2014 [SLP(C) Diary No(s). 30718/2023]).