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TMI Blog2023 (10) TMI 705X X X X Extracts X X X X X X X X Extracts X X X X ..... ay Kumar, Sr Standing Counsel with Ms Easha and Ms Hemlata Rawat, Advs. For the Respondent Through: None. RAJIV SHAKDHER, J. (ORAL): CM No.49729/2023 in ITA 553/2023 1. Allowed, subject to just exceptions. CM No.49728/2023 in ITA 552/2023 CM No. 49730/2023 in ITA 553/2023 [Applications filed on behalf of the appellant seeking condonation of delay of 120 days in re-filing the appeal] 2. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat it also dealt with AY 2013-14, besides the AYs referred to hereinabove. The Tribunal, thus, dealt with three appeals, which were preferred against the order dated 13.11.2017 passed by the Commissioner of Income Tax (Appeals) [in short, "CIT(A)"]. 8. The record shows that a search was conducted qua a group known as the J.P. Minda Group under Section 132 of the Income Tax Act, 1961 [in short, " ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bstantive basis qua AY 2011-12. 13. As regards AY 2012-13, Rs. 6,60,00,000/- was added on protective basis. 14. The Tribunal notes after it examined the record that the CIT(A) had returned a finding that the subject transactions, which involved investment in the companies which formed the J.P. Minda Group, were genuine. 14.1 The Tribunal also noted that the CIT(A) had concluded that neither had ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndered by the coordinate bench of this court in a bunch of appeals, including ITA No. 360/2022, titled Pr. Commissioner of Income Tax (Central) - 2 v. Jay Fe Cylinder Ltd. 18. A perusal of the aforesaid order shows that the court had concluded that no incriminating material was found qua the investment companies vis-à-vis which search was conducted by the appellant/revenue. 19. We may no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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