TMI Blog2014 (8) TMI 1194X X X X Extracts X X X X X X X X Extracts X X X X ..... ature, has to be admitted. However, this issue was not raised by the assessee before the AO and the CIT(A). Accordingly, we are of the view that it shall be in the interest of justice to restore this issue to the file of the AO with direction to decide about the legal issue regarding legality of the notice dated 13.6.2008 issued by the DCIT after allowing reasonable opportunity of hearing to the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -2005 is directed against the order of the CIT(A). 2. The concise ground no.1 of the appeal of the assessee is as under: 1. The CIT(A) erred in not quashing the order passed by the AO. The order be quashed. 3. The learned counsel for the assessee submitted that the notice under section 153C r.w.s. 153A was issued in this case after expiry of two years from the date of search on 10.5.200 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e CIT(A). Accordingly, we are of the view that it shall be in the interest of justice to restore this issue to the file of the AO with direction to decide about the legal issue regarding legality of the notice dated 13.6.2008 issued by the DCIT after allowing reasonable opportunity of hearing to the assessee. 5. Other concise grounds of the appeal of the assessee are as under: 2.0 The CIT(A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the purpose of earning income and therefore deductible in computation of income. 6. The learned counsel for the assessee submitted that the main issue in this ground of the appeal is regarding addition made of ₹ 17,54,784/- under section 68 of the Act. He submitted that in the connected case of M/s.Navratna Organizers Developers P. Ltd., the issue has been restored by the Tribunal t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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