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2017 (7) TMI 803 - AT - Income TaxAssessment u/s 153C - Held that:- CIT(A) clearly mentioned that the assessment order nowhere mentions any part of seized material belonged to Assessee Company, but the seized material is that of associates/group companies of BPTP Group. The assessee is also group company of the BPTP Group. This fact was never denied by the assessee at any point of time. The reliance by the Ld. AR on the order of M/s. Westline Developers Pvt. Ltd. is of no help to the assessee as the distinguishing factor has been pointed out by the Revenue. The present case is regarding Section 143(3) thus the facts are different from the ratio laid down in case of Westline Developer Pvt. Ltd.. The CIT (A) has rightly made observations that there is concrete evidence in form of seized material to show that interest is paid and received by seller on the extension of PDCs while analysing the seized documents. The CIT(A)’s order is upheld.
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