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TMI Blog2014 (11) TMI 1189X X X X Extracts X X X X X X X X Extracts X X X X ..... Respondent : Ms. Priscilla Singsit, CIT-III (DR). ORDER Per BENCH: All these appeals have been filed by the assessee against the common order of the CIT(A)-VI, Bangalore, dated 28/02/2014 for the assessment years 2005-06 to 2011-12. In all these appeals, one of the grounds raised by the assessee is against the validity of the search and the assumption of jurisdiction u/s 153A read with sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rt without making any comments on the facts stated by the assessee as regards non-existence of grounds for issuance of warrant. Thus, according to him, by remaining silent, the AO has accepted the contentions raised by the assessee with regard to the grounds not existing for issuance of warrant of search. He submitted that the CIT(A), in spite of the above silence of the AO, has rejected the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the rival contentions and the material on record, we find that the assessee has raised an additional ground of appeal particularly against the existence of conditions for issuance of warrant of search and the validity of the assumption of jurisdiction u/s 153A read with section 143(3) of the Act. In the remand report to the said additional grounds raised by the assessee, the AO has clearly not onl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of the additional ground of appeal relating to the validity of the jurisdiction u/s 153A as well as the existence of conditions for issuance of warrant u/s 132A of the Act. The other grounds of appeal raised by the assessee with regard to the merits of the disallowance of the addition made by the AO and as confirmed by the CIT(A) , are not adjudicated at this stage and the assessee shall be at ..... X X X X Extracts X X X X X X X X Extracts X X X X
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