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2016 (7) TMI 1361
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.... R.S. Syal, This appeal filed by the assessee arises out of the order passed by the CIT(A) on 24.12.2013 in relation to the assessment year 2007-08. 2. The only issue raised in this appeal is against the confirmation of disallowance of a sum of Rs. 8,40,000/- u/s 40A(3) of the Act on the ground that the AO did not have any jurisdiction to pass the assessment order u/s 153A. 3. B....
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....material found during the course of search. It was submitted that such a disallowance is unwarranted because the assessment for the instant year already stood completed on the date of search. In support of this proposition, he relied on the judgment of the Hon'ble Delhi High Court in CIT vs. Kabul Chawla (2016) 380 ITR 573 (Del). In the opposition, the ld. DR relied on the impugned order. 5. We....
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....ce u/s 143(2) was issued for completing assessment u/s 143(3). It indicates that the assessment for the instant year stood completed on the date of search. Going by the verdict given by the Hon'ble Delhi High Court in the case of Kabul Chawla (supra) that no addition can be made otherwise than those based on incriminating material found during the course of search in the case of completed assessme....