2020 (10) TMI 1390

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....acts. 2. On the facts and circumstances of the case, the CIT(A) has erred in deleting the addition u/s 68 of the Act amounting to Rs.8,46,11,456/-. 3. On the facts and circumstances of the case, the CIT(A) has erred in relying on the order of Hon'ble Delhi High Court in case of Kabul Chawla as Section 153A does not restrict the assessment to seized document." 3. In ITA No. 3142/Del/2017, following grounds have been raised by the assessee: 1. That the learned CIT (A) has erred both on facts and in law in upholding the validity of the order of assessment. 2. That the learned CIT(A) has further erred in not admitting the additional evidence furnished by the assessee (on an application made under Rule 46A of I.T. Rules) despite the....

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....ssessee. " 4. The facts relevant for the adjudication of the grounds raised by the revenue are as under: A Search and seizure action was conducted on the Vatika group of cases on 16.01.2013. The assessee who is individual involved in the business affairs of Vatika group was also covered u/s 132 of the Income Tax Act, 1961. The Assessment was completed u/s 153A of the Income Tax Act, 1961. After examining the return of income, the A.O. made addition of Rs. 8,46,11,456/- in respect of loans and advances received during the year. The assessment pertains to the assessment year 2006-07. The assessment in question is not an abated assessment as per the provisions of Section 153A of the Act. The loans & advances have been duly reflected in the ....