TMI Blog2017 (7) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... :- Tribunal has dismissed the Revenue's appeal by following the decision of this Court in CIT Vs All Cargo Logistic Ltd Corporation [ 2015 (5) TMI 656 - BOMBAY HIGH COURT] Where no assessment has been completed under Section 143(1) and only processing of returns is done, the AO is competent to invoke the jurisdiction under Section 153A/153C of the Act and complete the assessments followin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 06-2007. 2. The Revenue has urged the following substantial questions of law for our consideration:- (A) Whether on the facts and circumstances of the case and in law, the learned ITAT erred in deciding that it was not open to the Assessing Officer to make additions in the assessment under Section 153A r.w.s. 143(3) without the existence of any incriminating documents found or seized during ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in law, the learned ITAT has erred in not deciding the issue on merits without taking into consideration the decision of the Pune ITAT in the case of Kranti Realtors P. Ltd. (ITA No.2021 to 2023/PN/2013 dated 10.11.2015), wherein it was held that the decision of this Court in CIT Vs Continental Warehousing Corporation is on 'completed basis' and where no assessment has been completed under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... found with the same. 3. Mr. Bhattad learned counsel for the Revenue states that as the Revenue has filed an appeal against the order of this Court in All Cargo Logistics Ltd. (supra) and in Gurinder Singh Bawa (supra) in the Hon'ble Apex Court, this appeal has been filed to keep the issue alive. 4. In view of the above, the question of law as proposed do not give rise to any substantial ..... X X X X Extracts X X X X X X X X Extracts X X X X
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