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2022 (2) TMI 169 - AT - Income TaxAssessment u/s 153A - Addition on account of unsecured loan and on account of share application - proof of incriminating material for the relevant assessment year found or not? - HELD THAT:- As decided in own case [2021 (12) TMI 550 - ITAT DELHI] satisfaction note recorded by the AO does not mention or is based on any seized material belonging to the assessee company and consequently, the additions made by the AO has no co-relation with any seized material. The aforesaid finding of the Learned CIT(A) has not been rebutted by any material placed on record. Therefore, the aforesaid findings of Learned CIT(A) is based on legal principles upheld by the Hon”ble Jurisdictional High Court as well as Supreme Court in the case of PCIT vs. Sinhgad Technical Education Society [2017 (8) TMI 1298 - SUPREME COURT] - Thus the ground of Revenue is dismissed.
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