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2017 (4) TMI 718 - AT - Income TaxAssessment u/s 153A - addition to income - Held that:- On perusal of the satisfaction note as well as the reply of the assessee dated 29.11.2011 we do not find any reference to the amount of ₹ 15 lakhs pertaining to Savsuvida which is on account of advance against capital against the project finance agreement. Furthermore, the seized documents also do not referred to the issue of depreciation, travelling expenses, loss on sale of car as well as of not allowing carry forward of losses. Admittedly, the assessment for the present case was not pending at the time of search because the impugned assessment year is 2005-06 for which the due date of issue of notice expired on 31.03.2007. the date of search is 26.11.2009 therefore, obviously, on the date of search the assessment for the year under appeal was concluded. In the present case looking at the satisfaction note we do not find any material pertaining to the additions made by the ld Assessing Officer as well as no such material was put to our attention by the ld AR on the impugned additions. Therefore, we do not find any infirmity in the order of the ld CIT(A) in holding that there is no incriminating material unearth during the course of search which related to the addition and then deleting the addition. - Decided in favour of assessee
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