2011 (6) TMI 12

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....J.P. DEVEDHAR, J.)   1. Whether the ITAT was justified in setting aside the order passed by the CIT under Section 263 of the I.T. Act is the question raised in this appeal.   2. In the present case, based on the documents seized from the premises of Vishwas R. Bhoir, addition of Rs.90 lakhs were made in the hands of the respondent-assessee as undisclosed income in the block assessment ....

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....ter due consideration of both the documents referred to by the CIT. The Tribunal has recorded a finding of fact that the two documents cannot be read independent of each other. The Tribunal has further recorded a finding of fact that once the taxability under both the documents have been considered by the assessing officer and also by the CIT(A), it is not open to the CIT to invoke the jurisdictio....