TMI Blog2017 (2) TMI 346X X X X Extracts X X X X X X X X Extracts X X X X ..... had disclosed all the materials which came to be reviewed subsequently in Section 153A proceedings. Thus, having regard to the the decision in Kabul Chawla [2015 (9) TMI 80 - DELHI HIGH COURT] in the absence of seizure of any incriminating material, the ITAT, in this Court’s opinion, did not fall into error in quashing the proceedings - ITA 821/2016, ITA 822/2016, C.M. APPL.43364/2016 - - - Dated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1, search and seizure proceedings took place in the assessee s premises. Concededly, no new materials much less incriminating material, were unearthed. Nevertheless, based upon the existing material, the AO referred the matter to the TPO under Section 92C on the basis of an opinion that one of the transactions, i.e advance to the Associated Enterprise on interest-free basis ought to have attrac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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