2022 (5) TMI 418

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... he seized material. It is settled law that the issue of jurisdiction goes to the roots of the cause and such an issue can be raised at any belated stage of the proceeding including appeal. (See: Kanwar Singh Saini vs High Court of Delhi [ 2011 (9) TMI 960 - SUPREME COURT] And M/s Mavany Brothers vs. CIT [ 2015 (10) TMI 1093 - BOMBAY HIGH COURT] Consequently, this Court is of the view that .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... s that ITAT has further erred in deleting the addition on the issue of jurisdiction under Section 153A of the Act without adverting to the facts and merits of the addition. 3. He emphasises that ITAT was not justified in law in not appreciating the fact that in the first round the case was remanded back to the Assessing Officer for fresh adjudication on merits of the addition. He further states .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X