2023 (12) TMI 294

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....1754, 1744 and 1745/Del/2023 are three separate appeals by the revenue preferred against the order of the CIT(A)- 27, New Delhi dated 20.03.2023 pertaining to A.Y. 2011-12, 2012-13 and 2014-15. 2. Since the CIT(A) has decided the captioned appeals by a consolidated order and since in the captioned appeals have common grounds, therefore, they are disposed of by this common order for the sake of co....

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....rd consequence resulting in assessment under section 153C for the assessment years (i.e. AY 2018-19 & AY 2019-20), which fall later than search year (i.e. FY 2016-17), for which, no material can be found during the search on the relevant date. 3. The Ld. CIT(A), Delhi has erred on facts and in law, while not appreciating that the origin of action under Sections 153A and 153C lies in the same sea....

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....r Section 153A. 5. The Ld. CIT(A), Delhi has erred on facts and in law, in view of the Hon'ble Supreme Court Judgment in the case of Pr. CIT, Central-3 vs M/s Abhisar Buildwell Private Limited dated 24.04.2023, wherein legal position on the issue has been settled by holding that for conducting assessments under sections 153A/153C of the Act, there must be incriminating evidence indicating un....