TMI Blog2016 (10) TMI 626X X X X Extracts X X X X X X X X Extracts X X X X ..... ecorded by the AO, the said documents were stated to “pertain” to the Assessee and not belong to it. It is further pointed out by Mr. Arvind Kumar, and rightly, that the amendment to Section 153C which replaced the words “belong or belongs to” with the words “pertain or pertains to” was made only with effect from 1st June, 2015 whereas the search in the present case took place on 9th September 201 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mber, 2015 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No.6205/Del/2013 in C.O. No.150/Del/2014 for the Assessment Year ( AY ) 2009-10. 3. The question that is sought to be urged is whether the ITAT erred in holding that the assessment framed by the Assessing Officer ( AO ) under Section 143(3) read with Section 153C of the Income Tax Act, 1961 ( Act ) was invalid? 4. A searc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... addition on account of interest were deleted. 6. An appeal was filed by the Revenue and a cross-objection by the Assessee before the ITAT. The cross objection by the Assessee was specific to the issue of two documents stated to have been recovered during the search which did not belong to the Assessee and, therefore, could not form the basis for initiating proceedings against the Assessee under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... note recorded by the AO, the said documents were stated to pertain to the Assessee and not belong to it. It is further pointed out by Mr. Arvind Kumar, and rightly, that the amendment to Section 153C which replaced the words belong or belongs to with the words pertain or pertains to was made only with effect from 1st June, 2015 whereas the search in the present case took place on 9th Septem ..... X X X X Extracts X X X X X X X X Extracts X X X X
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