2021 (3) TMI 1066

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.... For the Revenue : Shri Satpal Gulati, CIT-DR ORDER PER BHAVNESH SAINI, J.M. This appeal by Revenue has been directed against the Order of the Ld. CIT(A)-3, Gurgaon, Dated 31.03.2017, for the A.Y. 2012-2013, on the following grounds : (i) Whether on the facts and circumstances of the case, the Ld. CIT(A) erred in law in allowing the appeal of the assessee quashing the assessment ....

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....11.2012. Survey action under section 133A of the I.T. Act, 1961 were also carried-out at the business premises of the assessee. The cases were centralized. The A.O. issued notice under section 153A r.w.s. 153C of the I.T. Act, 1961 for taking-up the case of the assessee under section 153C of the I.T. Act, 1961. The A.O. after considering the issue in detail, made an addition of Rs. 3 crores under ....

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....tion under section 153C of the I.T. Act, 1961. The assessee also relied upon Judgment of the Hon'ble Delhi High Court in the case of CIT vs., RRJ Securities Ltd., 128 DTR 57 (Del.). The Ld. CIT(A) also referred to Board Circular No.24/2015 in which the clarification was issued regarding recording of satisfaction under sections 153C/158BD of the I.T. Act, 1961. The Ld. CIT(A) in view of the above f....

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....isfaction note was not recorded by the AO of the search person in this case, the other grounds of appeal relating to the merit of this case are not being considered." 4. The Ld. D.R. relied upon the Order of the A.O. 5. The record reveal that this appeal was heard by ITAT, Delhi Bench on 20.02.2020 and thereafter fixed for clarification many times. Ultimately on 15.01.2021 the Ld. D.R. sough....