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2020 (12) TMI 739 - HC - Income TaxAssessment u/s 153C - it is contended that addition could be made in absence of any incriminating material found during the course of search. - HELD THAT:- It is clearly discernable that the ITAT has given a finding of fact that the assessments make no reference to the seized material or any other material for the years under consideration, that was found during the course of search, in the case of the assessee. Mr. Maratha is also unable to point out any incriminating material related to the assessee which could justify the action of the Revenue. Merely because a satisfaction note has been recorded, cannot lead us to reach to this conclusion, especially when the Revenue has not laid any foundation to support their contention. In the factual background as explained above, the assumption of jurisdiction under Section 153C cannot be sustained in view of the decision of this Court in the case of Kabul Chawla [2015 (9) TMI 80 - DELHI HIGH COURT].
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