2016 (10) TMI 626

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....sari, Advocate For the Respondent : Mr Arvind Kumar, Advocate ORDER CM No. 21925/2016 1. Since the amendment application is filed at an initial stage of the appeal i.e. before notice is issued, the application is allowed. The amended memo of appeal is taken on record. ITA 323/2016 2. The Revenue has filed this appeal against the order dated 23rd November, 2015 passed by the Incom....

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....5. Before the Commissioner of Income Tax (Appeal) ['CIT(A)'], the question of validity of the assessment was also challenged by the Assessee apart from the merits of the additions. By the order dated 18th September, 2013, the CIT(A) rejected the challenge to the validity of the assessment. However, the additions on the bogus purchases of raw materials and the addition on account of interest were d....

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....in law. 7. Mr. Rahul Chaudhary, learned Senior Standing counsel for the Revenue submitted that the two documents in question recovered in the search of the "Amrapali Group" should be taken to belong to the Assessee which is a part of the said Group. Mr. Arvind Kumar, learned counsel for the Assessee, on the other hand pints out that even in the satisfaction note recorded by the AO, the said doc....