2021 (3) TMI 1317

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....by : Shri Virendra Ojha, CIT-DR ORDER PER RAJPAL YADAV, VICE-PRESIDENT: Present two appeals are directed at the instance of the assessees against separate orders of the ld.CIT(A)-11, Ahmedabad of even dated i.e. 2.8.2018 passed on the respective appeals of the appellants in the Asstt.Year 2011-12. 2. Both the appellants have raised a common grievance viz. notice issued under section 153C of....

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....searched person, which indicated that such information pertains to or relates to these two assessees. Accordingly, action under section 153C of the Act has taken against the present assessees. 4. Dissatisfied with the assessment orders, both the assessees went in appeals before the first appellate authority. They have challenged jurisdiction of the AO assumed under section 153C of the Act on the ....

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....6. During the course of hearing, we have confronted the ld.counsel for the assessee as to why record a finding which otherwise academic in nature, because the additions made by the AO stands deleted by the ld.first appellate authority on merit. The orders of the CIT(A) in both the cases have attained finality as the appeals of the Revenue were dismissed on account of low tax effect involved in the....

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....bmitted that since in the satisfaction note recorded by the AO of the searched person depicts that he made reference to the information which pertains to the assessee, however, the assessment orders involved in the present appeals are concerned, in those years information should belong to the assessee. In other words, some documents ought to have been recovered which belong to the assessee, only t....