9911796707
TMI Blog2023 (12) TMI 294X X X X Extracts X X X X X X X X Extracts X X X X ..... .1754, 1744 and 1745/Del/2023 are three separate appeals by the revenue preferred against the order of the CIT(A)- 27, New Delhi dated 20.03.2023 pertaining to A.Y. 2011-12, 2012-13 and 2014-15. 2. Since the CIT(A) has decided the captioned appeals by a consolidated order and since in the captioned appeals have common grounds, therefore, they are disposed of by this common order for the sake of c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urd consequence resulting in assessment under section 153C for the assessment years (i.e. AY 2018-19 & AY 2019-20), which fall later than search year (i.e. FY 2016-17), for which, no material can be found during the search on the relevant date. 3. The Ld. CIT(A), Delhi has erred on facts and in law, while not appreciating that the origin of action under Sections 153A and 153C lies in the same se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er Section 153A. 5. The Ld. CIT(A), Delhi has erred on facts and in law, in view of the Hon'ble Supreme Court Judgment in the case of Pr. CIT, Central-3 vs M/s Abhisar Buildwell Private Limited dated 24.04.2023, wherein legal position on the issue has been settled by holding that for conducting assessments under sections 153A/153C of the Act, there must be incriminating evidence indicating u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not find any merit in the grievance of the revenue. If the revenue is aggrieved by the binding decision of the Hon'ble Jurisdictional High Court of Delhi (supra) the revenue may approach the Hon'ble Supreme Court but in no case the revenue can be aggrieved by the binding decision before this Tribunal. 5. In the result, the captioned appeals are dismissed. 6. Decision announced in the open court ..... X X X X Extracts X X X X X X X X Extracts X X X X
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