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2022 (5) TMI 418 - HC - Income TaxAssessment u/s 153A - Addition u/s 68 - addition based on seized material or not? - HELD THAT:- Admittedly, the present case is covered by the decision of the Division Bench in CIT vs Kabul Chawla [2015 (9) TMI 80 - DELHI HIGH COURT]as the additions were not based on the seized material. It is settled law that the issue of jurisdiction goes to the roots of the cause and such an issue can be raised at any belated stage of the proceeding including appeal. (See: Kanwar Singh Saini vs High Court of Delhi [2011 (9) TMI 960 - SUPREME COURT] And M/s Mavany Brothers vs. CIT [2015 (10) TMI 1093 - BOMBAY HIGH COURT] Consequently, this Court is of the view that no substantial question of law arises for consideration in the present appeal.
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