2022 (6) TMI 1013

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....Appeals)-19, Chennai [CIT(A)] dated 27.09.2017 in the matter of assessment framed by Ld. Assessing Officer [AO] u/s.153C r.w.s. 153A of the Act on 24.03.2015. 2. The Ld. AR, at the outset, drawing attention to Ground No.2 & 5 submitted that the assessment for this year is bad-in-law. The Ld. AR referred to the provisions of Sec.153C to support the arguments and submitted that there was no incriminating material that belonged to the assessee. Further, there was no satisfaction note in this regard. Ground No.2 read as under: - 2. For that the learned Commissioner of Income tax (Appeals) erred in rejecting the fact that the proceedings-initiated u/s 153C r.w.s. 153A was without jurisdiction under the facts and circumstances of the ....

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.... AO is satisfied that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person and that Assessing Officer shall proceed against each such other person and issue notice and assess or reassess the income of the other person in accordance with the provisions of Section 153A, if that Assessing Officer is satisfied that the books of account or doc....

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....not be sustainable. Resultantly, aforesaid grounds stand allowed which render other grounds mere academic in nature. The appeal stand partly allowed in terms of our above order. Assessee's Appeal for AY 2012-13. 6. This appeal arises out of order of learned Commissioner of Income Tax (Appeals)-19, Chennai [CIT(A)] dated 26.09.2017 in the matter of assessment framed by Ld. Assessing Officer [AO] u/s. 153C r.w.s. 153A of the Act on 24.03.2015. The only grounds urged before us is with respect to confirmation of addition of Rs.14.90 Lacs. This addition stem from the fact that assessee was found to have introduced cash of Rs.91 Lacs with M/s Ultratech Housing Ltd. Out of the same Rs.76.10 Lacs was admitted. Regarding balance Rs.14.90 Lacs,....