TMI Blog2017 (7) TMI 1412X X X X Extracts X X X X X X X X Extracts X X X X ..... e additions in the assessment under Section 153A read with Section 143(3) without the existence of any incriminating documents found or seized during the search action under Section 132? - HELD THAT:- We find that the impugned order of the Tribunal has dismissed the Revenue s appeal before it by following the decision of this Court in CIT Vs All Cargo Logistic Ltd Corporation [ 2015 (5) TMI 656 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cember, 2016 passed by the Income Tax Appellate Tribunal (Tribunal). The impugned order relates to Assessment Year 2005-2006 and 2006-2007. This appeal relates to Assessment Year 2006-2007. 2. The Revenue has urged the following two questions of law for our consideration:- (A) Whether on the facts and circumstances of the case and in law, the Iearned ITAT was justified in not deciding the issue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... PN/2013 dated 10.11.2015), wherein it was held that the decision of this Court in CIT Vs Continental Warehousing Corporation is on 'completed basis' and where no assessment has been completed under Section 143(1) and only processing of returns is done, the AO is competent to invoke the jurisdiction under Section 153A/153C of the Act and complete the assessments following the procedure laid ..... X X X X Extracts X X X X X X X X Extracts X X X X
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