TMI Blog2017 (12) TMI 1362X X X X Extracts X X X X X X X X Extracts X X X X ..... for initiating proceedings against the Assessee under Section 153 C of the Act. Even in the satisfaction note recorded by the AO, the said documents were stated to “pertain” to the Assessee and not belong to it. 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 i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat this precise question was urged in ITA 323/2016 - which concerned the same search block assessments. The Court had then declined to entertain the appeal stating as follows: - 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions 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 crossobjection 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 basi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the other hand pints out that even in the satisfaction 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 where ..... X X X X Extracts X X X X X X X X Extracts X X X X
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