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TMI Blog2021 (7) TMI 1163X X X X Extracts X X X X X X X X Extracts X X X X ..... as not been challenged by the Revenue in further appeal - adjudication of legal issue at this stage would only an academic exercise. It is not going to materially affect the assessee in any manner. No other proceedings, in consequence to this proceeding qua the assessee are pending. We do not deem it necessary to devote time energy for resolving an academic litigation. To our mind, to some extent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee against order of the ld.CIT(A)-11, Ahmedabad dated 21.8.2018 passed for the Asstt.Year 2011-12. 2. The grounds raised in the appeal of the assessee are descriptive in nature. In brief, grievance of the assessee is that the notice issued under section 153C of the Income Tax Act, 1961 upon the assessee and asking it to file return of income, was illegal and without jurisdiction. Therefore, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed assessment order on 30.12.2016. He determined taxable income as under: "6. After examination of the details, and discussion held with the AR of the assessee & as in preceding paras of this order and subject to the details made available by the assessee, the total income of the assessee is computed as under: Income as shown by the assessee Rs. 201640 Add back u/s 69 unexplained credit en ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bmitted that this issue will crop up in the case of large number of assessees because notices under section 153C have been issued on number persons. Therefore, it is necessary to record a finding on the legal issue. 6. On due consideration of the above facts and circumstances, we are of the view that addition made by the AO has already been deleted by the CIT(A) on merit. The order of the CIT(A) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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