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M/s. Tech Pacific (India) Ltd. (Now known as Ingram Micro India ltd.) Versus The DCIT, (OSD) -II

2015 (7) TMI 1116 - ITAT MUMBAI

Assessment made u/s. 153A - additions to income - Held that:- It is an undisputed fact that there was no incriminating material found during the search for making the impugned disallowances/additions. See Continental Warehousing Corporation and All C .....

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Shri J.D. Mistry And Shri Nishant Thakkar Respondent by: Shri Manjunatha Swamy ORDER PER N.K. BILLAIYA, AM: These three appeals are by the assessee preferred against the very same order of the Ld. CIT(A)-40, Mumbai dt. 05.01.2011 pertaining to Assess .....

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ssee stated that ground No. 1 in all these appeals challenges the jurisdiction of the Officer for making an assessment u/s. 153(A) of the Act. It is the say of the Ld. Counsel that this issue has been decided in favour of the assessee and against the .....

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followed and ground No. 1 is allowed, the other grounds of appeal will become otiose. 3. Per contra, the Ld. Departmental Representative could not bring any distinguishing decision in favour of the Revenue. 4. Briefly stated the facts of the case ar .....

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search/survey actions resulted into seizure and impounding of documents, loose papers and other material evidencing the irregularities relating mainly to international tax. 4.1. The assessment for A.Y 2002-03 was completed by disallowing bad debts c .....

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imilar heads though with different quantum and the same is done in A.Y. 2004-05. 5. Aggrieved by the assessments, the assessee carried the matter before the Ld. CIT(A) but without any success. 6. Before us, the Ld. Counsel for the assessee stated tha .....

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would confer upon the AO the power to review or revise his own order. It is the say of the Ld. Counsel that this proposition has been confirmed by the Hon ble High Court of Bombay in the case of Continental Warehousing Corporation and All Cargo Glob .....

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found during the search for making the impugned disallowances/additions. The ratio laid down by the Hon ble Jurisdictional High Court (supra) squarely apply on the facts of the case wherein the Hon ble High Court has held as under: Held, dismissing t .....

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