2018 (5) TMI 2052

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....n and Mr. Raghvendra Singh, Advocates for Revenue. For the Respondent : None ORDER MR. A. K. CHAWLA, JJ. These appeals of the Revenue challenge the findings of the ITAT. The ITAT reversed the addition made by the Assessing Officer (AO) in the course of the scrutiny of the assessment primarily on the ground that no fresh relating material was discovered during the search and seizure pro....

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....same had been added by the AO in the assessment made u/s 143 (3) of the Act. It is also seen that the assessee had preferred an appeal before the Ld. CIT (A) who had deleted these additions and on further appeal by the Department, ITAT Agra Bench had also upheld the CIT (A)'s order in ITA Nos. 142 and 153/Agr/2008. Subsequently, revenue's appeal before the Hon'ble High Court was also dismissed vid....

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....er given by the first proviso to assess income for six assessment years has to be confined to the undisclosed income unearthed during search and cannot include items which were disclosed in the original assessment proceedings. A perusal of the assessment order passed u/s 153A of the Act reveals that the AO has not made any reference whatsoever to any incriminating material found as a result of the....