2019 (5) TMI 1711

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....22nd June 2018 passed by the ITAT in ITA No.6246/Del/2014 for the Assessment Year 2006-07. 2. The question urged by the Revenue is whether the CITA and ITAT) were right in holding that the assumption of jurisdiction under Section 153C of the Income Tax Act, 1961 (Act) qua the passing of the order under Section 153A/153C of the Act was not in accordance with law since there was no incriminating ....

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....ildwell Pvt. Ltd. That amount was in fact added since it was shown sourced from different entities of Jain Brothers and had failed to pass the test of genuineness of transactions under Section 68 of the Act. 4. The ITAT has deleted the said addition for the simple reason that the above addition was not based on the satisfaction note prepared for the purposes of initiation of proceedings against....