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Issues involved:
The judgment involves appeals and cross objections related to assessments completed under sec.153A read with section 153C read with section 143(3) of the Income-tax Act, 1961 for the assessment years 2002-03, 2003-04, 2004-05, 2005-06, and 2006-07. Assessment of Lease Income: The Revenue contended that the assessee had not disclosed income earned from leasing buses, leading to assessments based on lease agreements found during a search. However, the Commissioner of Income-tax (Appeals) noted that the assessee maintained proper books of account supported by vouchers and bills, directing the Assessing Officer to consider income as per these books rather than the lease agreements. Validity of Notices and Interest Levy: The assessee challenged the validity of notices issued u/s 153A, re-assessments, and the levy of interest under sec.234A and 234B. The Commissioner of Income-tax (Appeals) upheld the notices and interest levy, leading to cross objections by the assessee on these grounds. Revenue's Grounds and Assessee's Cross Objections: The Revenue raised common grounds for all assessment years, questioning the deletion of additions related to lease income and other sources, which the Commissioner of Income-tax (Appeals) had allowed. The assessee's cross objections focused on challenging the legality of the notice u/s 153A and the levy of interest under sec.234A and 234B. Decision and Rationale: The Tribunal upheld the Commissioner's decision to accept the income returned by the assessee as per her maintained books of account, dismissing the Revenue's appeals. Regarding the cross objections, the Tribunal agreed with the Commissioner's findings on the validity of notices and interest levy, leading to the dismissal of the assessee's objections as well. Conclusion: Both the appeals and cross objections were dismissed, affirming the orders of the Commissioner of Income-tax (Appeals) regarding the assessment of income and the validity of notices and interest levy.
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