Brand new AO in addition to stated that particular other businesses have been indulged into the providing holiday accommodation records and you may Assessee business becoming certainly recipient of such records, financing said to were gotten regarding told you enterprises was being managed while the unexplained borrowing below Section 68 of your own Operate

S. 153C: Analysis – Income of every other person – Browse – Evaluation significantly less than S. 147/S.148 – gap ab initio

This new Assessing Officer initiated re also- evaluation process u/s 147 of one’s Operate relying on the information received mainly based on the certain files discovered in the course of research away from the newest site off an authorized. Ergo, the fresh testing would depend up on the brand new files discover when you look at the direction from browse out-of 3rd party site, however, that can easily be made merely u/s 153C of Act. The fresh new supply out of Point 153C of the Operate is actually attracted when discover one incriminating data files over brand new assessee which are found inside the research of 3rd party premises. 147 of Operate, ergo, invoking the brand new arrangements off Sec. 147, instead of 153C of the Act is apparently incorrect when you look at the legal parlance. (mais…)