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TMI Blog2018 (8) TMI 278X X X X Extracts X X X X X X X X Extracts X X X X ..... BHATT(174) For The RESPONDENT : MR B S SOPARKAR(6851) ORAL JUDGMENT (PER : HONOURABLE MR.JUSTICE M.R. SHAH) [1.0] Feeling aggrieved and dissatisfied with the impugned common judgment and order passed by the learned Income Tax Appellate Tribunal, Ahmedabad "B" Bench, Ahmedabad (hereinafter referred to as "the learned Tribunal") in respective Tax Appeals, being IT(SS)A No.674/Ahd/2010 & CO No ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT(A) deleting the addition of Rs. 43,15,624/- made by the Assessing Officer? [2.0] Ms. Mauna Bhatt, learned advocate appearing on behalf of the revenue has submitted that the learned Tribunal seems to have proceeded on erroneous findings that no satisfaction was recorded by the Assessing Officer of the searched person, and therefore, no cognizance under Section 153C of the Income Tax Act could ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... notice issued by this Court, Shri B.S. Soparkar, learned advocate has appeared on behalf of the respondent - assessee. He has submitted that before the learned Tribunal even the Deputy Commissioner of Income Tax, Central Circle 1 (3), Ahmedabad vide communication dated 19/09/2017 addressed to the Commissioner of Income Tax, ITAT -2, Ahmedabad also stated as under; "It is to submit that, on verif ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ere was a satisfaction recorded or not and thereafter proceedings under Section 153C of the Income Tax were initiated or not and whether the learned Tribunal and the departmental representative proceeded further erroneously and /or on erroneous facts, it may firmly be brought to the notice of the learned Tribunal by way of rectification application so that the learned Tribunal may consider the fil ..... X X X X Extracts X X X X X X X X Extracts X X X X
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