TaxTMI 
TaxTMI 
2025 (1) TMI 496
X X X X Extracts X X X X
X X X X Extracts X X X X
....onsolidated order, as a matter of convenience. 3. In addition to the main grounds, the assessee has raised the following additional grounds in all these appeals: Additional Ground Number 1: In the facts and circumstances of the case and in law, the Assessing Officer erred in wrongly recording satisfaction u/s. 153A even though no incriminating documents were found from the premises of the Appellant which ought to have belonged to the Appellant. Additional Ground Number 2: In the facts and circumstances of the case and in law, the Assessing Officer erred in the said disallowance tantamount to double addition of same income in the hands of the Appellant even though the same is already taxed in the hands of the respective partners. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... and seizure operation, a statement was recorded from Shri Dhanraj Balachand Vora, one of the partners, wherein a query was made regarding the nature of the work done by Ms. Chhaya D. Vora and Shri Yash Vora to entitle them for the remuneration. He observed that in response to such query, the concerned partner had submitted that the partners shall get remuneration as working partner. However, they did not come to office daily. It was stated that Ms. Chhaya D. Vora helps in accounts maintenance of the firm. Whereas, Shri Yash Vora helps in business. Relying upon such statement, the A.O. issued a show cause notice to the assessee, requiring to explain as to why the remuneration paid to Ms. Chhaya D. Vora should not be disallowed, as such expe....
X X X X Extracts X X X X
X X X X Extracts X X X X
....oncerned partner and such remuneration has already been taxed at the hands of the concerned partner no further disallowance can be made at the hands of the assessee. Thus, he submitted, additions made should be deleted. 10. The learned Departmental Representative ('ld. DR' for short), strongly relied upon the observations of the A.O. and learned first appellate authority. 11. We have considered rival submissions and perused the materials on record. As could be seen from the facts on record, the search and seizure operation on the assessee took place on 16.10.2019. Therefore, as on the date of search and seizure operation, no assessment proceeding for A.Ys. 2014-15 to 2018-19 were pending. Therefore, for such unabated assessment ye....