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TMI Blog2024 (6) TMI 261X X X X Extracts X X X X X X X X Extracts X X X X ..... Respondent : Shri Subhra Chakraborty, CIT- DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- This appeal by the assessee is preferred against the order of the ld. CIT(A)-26, New Delhi dated 13.11.2017 pertaining to A.Y. 2013-14. 2. The grievances of the assessee read as under: "1. The order of the Hon'ble Commissioner of Income Tax (A) is arbitrary, against law and facts on record. 2 The Ho ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he learned Assessing officer has failed to consider the fact that during the course of search no incriminating documents in respect of transaction appearing in the bank account have been found and as such addition made by the Assessing officer while passing the order u/s 153CI 143(3) is against the provision contained in the Income Tax Act, 1961. 5. The Hon'ble Commissioner of Income Tax (A) off ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2016 and placed strong reliance on the decision of the co- ordinate bench in one of the group cases Jagat Overseas ITA No. 5. The ld. DR could not controvert to the submissions of the ld. counsel for the assessee and placed strong reliance on the orders of the authorities below. 6. We have carefully considered the orders of the authorities below and have gone through the relevant material on rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Supreme Court in the case of Singhad Technical Education Society 397 ITR 344 squarely applies wherein the Hon'ble Supreme Court has held that for each A.Y of the block period, there should be separate incriminating material to frame assessment. This has been reaffirmed by the Hon'ble Supreme Court in the case of Abhisar Buildwell Pvt Ltd 454 ITR 212. 11. In light of the satisfaction note ..... X X X X Extracts X X X X X X X X Extracts X X X X
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