2020 (3) TMI 106

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.... namely learned CIT(A) has erred in deleting the addition of Rs. 2,39,55,483/- out of total addition of Rs. 2,62,08,519/-. 3. On the other hand, assessee has taken ten grounds of appeal. Assessee's grievances can be summarized under two folds, i.e. (i) the learned CIT(A) has erred in upholding the assessment order passed under Section 153C r.w.s. 153A of the Income-tax Act, whereas the Assessing Officer has no such jurisdiction to pass the assessment order and (ii) the learned CIT(A) has erred in confirming the addition at Rs. 22,53,036/- by estimating profit @ 10% in the alleged undisclosed receipt of Rs. 2,25,30,368/-. 4. Both the issues are interconnected with each other; therefore, we take them together. The brief facts of the case ar....

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....8,449/-. He made additions of these transactions by treating them as undisclosed income of the assessee. 6. On appeal, learned CIT(A) has estimated the profit element involved in alleged receipt and confirmed addition to the extent of Rs. 22,53,036/- being 10% of Rs. 2,25,30,368/-. 7. Before us, at the very outset, learned Counsel for the assessee submitted that for taking cognizance under Section 153C of the Incometax Act, the Assessing Officer of the searched person ought to have recorded a satisfaction exhibiting the fact that documents belonging to the assessee were found at the premises of the searched person during the course of search. These documents or evidences disclose undisclosed income of other person, i.e. assessee in the pr....