2021 (10) TMI 263

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....61(In short the 'Act') dated 13.11.2007 framed by ACIT, Bhopal. The Assessee has raised following grounds of appeal in IT(SS)ANo.01/Ind/2019: 1. That on the facts & in the circumstances of the case and in law, the initiation of proceedings u/s 153A are unlawful and without jurisdiction and, therefore, the assessment made be held as unlawful and without jurisdiction and hence be cancelled. 2. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred and is not justified in sustaining addition of Rs. 286561/- made by the AO as per para (5) of the assessment order the said unlawful and unjustified addition of Rs. 286561/- be kindly deleted. 3. That on the facts and in the circumstance....

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.... and assessed the income at Rs. 8,77,790/-. 4. Aggrieved assessee preferred an appeal before Ld. CIT(A) but could not succeed. 5. Now assessee is in appeal before this Tribunal. Ld. counsel for the assessee vehemently argued supporting the submissions filed before the ld. CIT(A), documents placed in the paper book running from pages 5 to 37 and also relying on the decision of this Tribunal in the case of Agarwal Jewellers (one of the group case where search was conducted) IT(SS)A No. 86/Ind/2012 dated 19.06.2012. 6. Per contra Ld. DR vehemently argued supporting the orders of both the lower authorities. 7. We have heard rival contentions and perused the records placed before us. Ground no.1 & 4 by the assessee are general in nat....