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2018 (5) TMI 56 - AT - Income TaxAssessment u/s 153C - documents belonging to the assessee or the assumption of jurisdiction by the AO - Held that:- As rightly pointed out by the learned CIT(A) Exhibit A11 is the letter written by M/s Gee Ispat P. Ltd. and was returned by the assessee by putting their signature and seal in confirmation of the accounts, as such it belongs to Gee Ispat and not the assessee. So also the list of shareholders contained in Exhibit A1 and index sheet in Exhibit A8 cannot be said to belong to the assessee inasmuch as besides assessee there are so many names and it cannot be said that these documents belong to them. It would lead to some absurd conclusions or consequences to say that when a person maintains a list of their shareholders, such document belongs to or pertains to such shareholders also. We find no reason to disturb these findings of the learned CIT(A). We are of the considered opinion that the findings of the learned CIT(A) on the aspect of the documents belonging to the assessee or the assumption of jurisdiction by the AO cannot be said to be either perverse or require any interference at the end of this Tribunal. We accordingly while upholding the same, find the grounds of appeal as devoid of merits. - Decided against revenue.
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