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Writ application challenging validity of assessment u/s 153C. Unexplained income to be taxed u/s 69A. Appellants instituted statutory appeals before Commissioner of Income Tax (Appeals), raising necessary grounds including jurisdiction aspect. Writ appeals dismissed as appellants impermissibly riding two horses. Observations in previous order not to impede adjudication of appeals as per law. Contention regarding addition of unexplained income u/s 69A to appellants' income found meritorious. Assessing authority to consider unexplained income u/s 69A afresh in accordance with law during de novo assessment, without being bound by previous direction.
Writ application challenging validity of assessment u/s 153C. Unexplained income to be taxed u/s 69A. Appellants instituted statutory appeals before Commissioner of Income Tax (Appeals), raising necessary grounds including jurisdiction aspect. Writ appeals dismissed as appellants impermissibly riding two horses. Observations in previous order not to impede adjudication of appeals as per law. Contention regarding addition of unexplained income u/s 69A to appellants' income found meritorious. Assessing authority to consider unexplained income u/s 69A afresh in accordance with law during de novo assessment, without being bound by previous direction.
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