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2021 (12) TMI 996 - HC - Income TaxAssessment u/s 153A/153C - jurisdictional benchmark of “belong to” under Section 153C - Whether Tribunal has failed to appreciate that seized material indicated that certain portion of the transaction was conducted out of book? - HELD THAT:- This Court finds that the very same document seized from the residence of Mr.Lalit Modi, had been considered by the learned predecessor Division Bench in the case of Principal Commissioner of Income Tax (Central -2) v. Vinita Chaurasia [2017 (5) TMI 992 - DELHI HIGH COURT]. After considering the same, the learned predecessor Division Bench had concluded that the Assessing Officer appears to have proceeded purely on conjecture as regards what the document states without noticing the internal contradiction and inconsistencies. Since the learned predecessor Division Bench has, on merits, found that there was no error committed by the Tribunal in deleting the addition made by the Assessing Officer on the basis of the same seized material/ document, this Court is of the view that in the present facts of the case, no substantial question of law arises for consideration
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