2025 (4) TMI 2061

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....AGANESH, ACCOUNTANT MEMBER For the Assessee : Sh. Somil Aggarwal, Adv. & Sh. Deepesh Garg, Adv. For the Revenue : Sh. Surender Pal Singh, CIT-DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: These twin assessee's as many appeals i.e. ITA No. 7349/Del/2017 and ITA No. 1771/Del/2019, for Assessment Years 2013-14 & 2014-15 arise against the CIT(A), Karnal's in case No. IT/75/GGN/201....

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....at the assessee's case was centralized in furtherance to the said search action and both the learned lower authorities thereafter proceeded as per the search record only. That being the case, we are of the considered view that once there already exists a specific provision of framing assessment in case of such a third person u/s 153C of the Act which is self-contained correctness itself wherein th....

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.... The Revenue draws strong support from both the lower authorities' action that once the assessee had fails to plead and prove all the relevant facts, the impugned selling expenditure could hardly be accepted. 6. The assessee's case on the other hand is that it was engaged in the business of trading of building material items, share & securities and real estate etc. wherein such selling expenses....