9911796707
TMI Blog2023 (10) TMI 705X X X X Extracts X X X X X X X X Extracts X X X X ..... on protective and substantive basis also affirmed by ITAT - HELD THAT:- As decided in Jay Fe Cylinder Ltd. [ 2022 (9) TMI 1330 - DELHI HIGH COURT] no incriminating material was found qua the investment companies vis- -vis which search was conducted by the appellant/revenue. Thus the appeal of the appellant/revenue need to be dismissed according to us, no substantial question of law arises for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a delay of 120 days. 3. Given the nature of delay and the reasons stated in the applications, the delay in re-filing the appeals is condoned. 4. The applications are disposed of, in the aforesaid terms. ITA Nos. 552/2023 553/2023 5. These appeals concern Assessment Year (AY) 2011-12 [ITA No.552/2023] and AY 2012-13 [ITA No.553/2023]. 6. Via the above-captioned appeals, the ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ngly, notice under Section 153C of the Act was issued to the respondent/assessee on 29.01.2016. 10. The record also shows that the respondent/assessee filed its return pursuant to the said notice, albeit, under protest. 11. A perusal of the impugned order dated 31.03.2016 framed under Section 143(3) read with Section 153C of the Act shows that the Assessing Officer had made additions under S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... companies falling under the sway of the J.P. Minda Group. 15. It is based on these observations that the CIT(A) had deleted the additions referred to hereinabove, made both on protective and substantive basis for the AYs in issue, i.e., AY 2011-12 and AY 2012-13. 16. The Tribunal affirmed the findings of fact returned by the CIT(A), by observing that the appellant/revenue could not bring an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... This is evident upon a perusal of the extract of the CIT(A) s order contained in paragraph 3 of the impugned order passed by the Tribunal. 20. Having regard to the finding of fact returned by CIT(A) and the Tribunal, as also the fact that the coordinate bench in the aforementioned matter has dismissed the appeal of the appellant/revenue, according to us, no substantial question of law arises f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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