Validity of search conducted by AO couldn't be challenged for first time during appeal after 3 years of search

INCOME TAX: Where assessee during first appeal disputed validity of search on ground that no panchas were present at time of search and recording of statement under section 132(4), since assessee had not raised such dispute before Assessing Officer, and it was raised for first time during first appeal which was after period of three years from search proceedings, impugned search could not be held to be invalid

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