2024 (6) TMI 261

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....come Tax (A) is arbitrary, against law and facts on record. 2 The Hon'ble Commissioner of Income Tax (A) has failed to consider that the issuance of notices u/s 153CI 142(1)/143(2) of the Income Tax Act, 1961 by the learned Assessing officer and the proceedings conducted there under are against the provisions contained in the Income Tax Act, 1961 and is bad in law and hence liable to be quashed. 3. The Hon'ble Commissioner of Income Tax (A) has erred in confirming addition of Rs. 75,00,000/- made on protective basis by the Assessing(officer without going through the facts of the case, statutory provisions as well as explanation filed during the course of assessment proceeding as well as during appellate proceeding and orde....

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....ould not controvert to the submissions of the ld. counsel for the assessee and placed strong reliance on the orders of the authorities below. 6. We have carefully considered the orders of the authorities below and have gone through the relevant material on record. 7. Briefly stated, the facts of the case are that search and seizure operation u/s 132 of the Income-tax Act, 1961 [the Act, for short] was conducted in Minda Group of cases on 20.09.2013. During the search and seizure operation, documents belonging to the assessee were also seized from the business and residential premises of the Minda Group. 8. Following satisfaction note was drawn by the ACIT, Central Circle-13, New Delhi: 9. It can be seen from the above satisfacti....