CANYON FINANCIAL SERVICES LTD. Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) These are five writ petitions filed by Canyon Financial Services Limited (hereafter 'the Assessee'), questioning the satisfaction notes dated 13th and 19th March, 2014 issued by the Deputy Commissioner of Income Tax ('DCIT'), Central Circle-2 New Delhi [hereinafter referred to the Assessing Officer ('AO') of the searched person'] and the Income Tax Officer, Ward 3(2), New Delhi [hereinafter 'AO of the Assessee'] respectively initiating proceedings against the Assessee under section 153C of the Income Tax Act, 1961 ('Act').

(2.) A search and seizure operation was carried out in the case of M/s. Dalmia Group of cases on 20th, 27th and 28th January 2012 by the Investigation Wing Unit-VI(1), New Delhi of the Income Tax Department ('Department'). In that process a search was undertaken of Mr. Parag Dalmia at Bhikaji Cama Place, New Delhi and documents comprising 249 pages were seized.

(3.) During the consequent assessment proceedings involving Dalmia Infrastructures Private Limited ('DIPL') [formerly known as Dalmia Equities Private Limited ('DEPL')], the AO of DEPL prepared on 13th March 2014 a satisfaction note in which set out in a tabular form an analysis of some of the documents seized as under: <IMG>JUDGEMENT_182_LAWS(DLH)7_2017.jpg</IMG>