9911796707
TMI Blog2016 (10) TMI 1033X X X X Extracts X X X X X X X X Extracts X X X X ..... s contentions are insubstantial. Unlike Section 148 which permits re-assessment for a completed previous year, in case tangible material available subsequently and which also further distinguishes between the return filed under Section 143(1) on the one hand and the scrutiny assessment on the other hand under Section 143(3), section 153A makes no such distinction. In other words, the basic premise ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the total income of ₹ 1,10,83,618/-. It involved an add back under Section 40(A) of the Income Tax Act. The order was confirmed by the CIT(A) who partly allowed the assessee''s contention. The assessee thereafter approached the ITAT. The ITAT by the impugned order accepted the assessee's contention and in the course of its order relied upon the reasoning of a Division Bench of this Court i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 143(3), section 153A makes no such distinction. In other words, the basic premise on which Kabul Chawla was decided i.e. that in the course of search and seizure proceedings there should be some new material forthcoming to permit addition in the Section 153A Block assessments, would squarely apply. Consequently, the revenue's contentions cannot be accepted. No question of law arises. Appeals ar ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
