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TMI Blog2020 (8) TMI 946X X X X Extracts X X X X X X X X Extracts X X X X ..... u/s 37(1) - as pointed assessment year in question was not abated as per Section 153A and the regular assessment had already been completed u/s 143(3) - HELD THAT:- As the regular assessment has already been completed u/s 143(3), the assessment has not been abated, the addition has not been made based on any incriminating material unearthed during the course of search or requisition of document o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... against the order of the ld. CIT(A), Karnal dated 06. 03.2017. 2. Following grounds have been raised by the assessee: "1. That having regard to the fact and circumstances of the case, ld. CIT (A) has erred in law and on facts in confirming the action of ld. AO in assuming jurisdiction and issuing of noti ce u/s 153A r.w.s. 153C of the Act, more so when the notice was issued in the name of non-e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... That having regard to the facts and circumstances of the case, ld. CIT (A) has erred in law and on facts in confirming the action of ld. AO in passing the impugned order without giving adequate opportunity of being heard." 3. Facts relevant to adjudication of the case are that a search & seizure action in the case of SRS Group of companies was conducted on 09. 05.2012. The notice u/s 153C in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome pertaining to the assessee found out during the search & seizure operation and in view of judgments in the case of CIT Vs Kabul Chawla 126 DTR 130 and CIT Vs Kurele Paper Mills Pvt. Ltd. 380 ITR 571 wherein it was held that the completed assessments cannot be interfered with by the AO while making the assessment u/s 153C in the absence of any incriminating material, the addition made by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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