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Pr. CIT Central-1, New Delhi Versus Amrapali Grand

2016 (10) TMI 626 - DELHI HIGH COURT

Validity of assessment u/s 153C - Held that:- 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 Section 15 .....

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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 2010 and the notice under Section 153C was issued .....

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: Mr Rahul Chaudhary, Senior Standing counsel with Mr Raghvendra Singh, Junior Standing counsel and Mr Anup Kumar Kesari, Advocate For the Respondent : Mr Arvind Kumar, Advocate ORDER CM No. 21925/2016 1. Since the amendment application is filed at a .....

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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 Office .....

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153C of the Act was issued to the Assessee, which is a partnership firm. In the ensuing assessment proceedings, the AO made an addition of ₹ 1,12,60,413/- on account of bogus purchases of raw materials and of ₹ 1,71,85,440/- on account o .....

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h September, 2013, the CIT(A) rejected the challenge to the validity of the assessment. However, the additions on the bogus purchases of raw materials and the addition on account of interest were deleted. 6. An appeal was filed by the Revenue and a c .....

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is for initiating proceedings against the Assessee under Section 153 C of the Act. The ITAT was of the view that the said document i.e. a chart at pages 53 and 54 of Annexure A-1 did not belong to the Assessee. Following the decisions of this Court i .....

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