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2019 (9) TMI 729 - ITAT DELHIAssessment u/s 153C - proof of incriminating material found in search - HELD THAT:- Conditions of Section 153C are not satisfied in this case. The A.O, therefore, rightly framed regular assessment u/s 143(3) after considering the incriminating material available on record. A.O. in para-2 with regard to addition of the interest on PDCs has mentioned that on perusal of the bills of payments of purchase consideration it was noticed that only part payments have been made while executing the sale deed and balance consideration was paid through PDCs. Therefore, the addition is made by the A.O. on the basis of the documentary evidences produced by the assessee with regard to the payments mentioned in the sale deed. A.O, therefore, correctly made assessment under section 143(3). A.O. has examined the evidences available on record and rightly came to the conclusion that assessee paid interest in cash on PDCS. CIT(A) on examination of the material on record in the light of seized material and others rightly directed the A.O. to compute interest from PDCs after six months from the date of issue of PDCs. D.R. relied upon the above decisions of the ITAT, Delhi Bench in which similar directions of the CIT(A) have been confirmed by the Tribunal. In this view of the matter and in the absence of any representation from the side of the assessee, we do not find any merit in the appeal of assessee and the same is accordingly dismissed. Appeal of Assessee dismissed.
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