2025 (2) TMI 1560

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.... ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: This assessee's appeal for Assessment Year 2013-14, arises against the CIT(A)-IV, Noida's in case No. CIT(A), Delhi-IV/10804/DCIT-CC/NOIDA/2015-16-787 dated 23.03.2018, in proceedings u/s 153C/143(3) of the Income Tax Act, 1961 (in short "the Act"). 2. Case called twice. None appears at the assessee's behest. It is accordingly proceeded ....

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....essee without which entire proceedings get vitiated. 1.3 That orders passed by Id. Assessing officer and Id. CIT(A) are invalid and unlawful because documents found in the search on 9/10/2013 as per applicable law under section 153C of the Act have not been proved to be belonging to the assessee in accordance with law, which make the satisfaction as invalid. 1.4 That orders passe....

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....IT(A) are invalid and unlawful because order passed u/s 153C/143(3) of the Act is dispatched on 01/04/2016, which is clearly barred by limitation as per section 153B of the Act. 2. That Id. CIT(A) grossly erred in confirming the addition of Rs. 20 Crore without appreciating that documents on which basis huge addition has been made has no evidentry value under section 292C and section 132(....

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....ties on basis of stated MOU, which never crystallized as such no evidence worth name has been brought so as to establish that said MOU has actually acted upon, accordingly entire proceedings ate conducted on basis of Dumb Documents, contents of which has never been proved to be acted upon. 2.3 That addition of Rs. 20 crore made. Confirmed by lower authorities on the basis of stated MOU, i....