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TMI Blog2024 (11) TMI 692X X X X Extracts X X X X X X X X Extracts X X X X ..... 017 (4) TMI 1194 - DELHI HIGH COURT] are applicable here in the present case. We, therefore, do not find any infirmity in the impugned order and thus, we decline to interfere with the finding of the Ld. CIT(A). Accordingly, the appeal of the Revenue is dismissed. - Shri Yogesh Kumar Us, Judicial Member And Shri Avdhesh Kumar Mishra, Accountant Member For the Appellant : Sh. Subhash Agarwal, Advocate For the Respondent : Ms. Jaya Choudhary, CI T-DR ORDER PER AVDHESH KUMAR MISHRA, AM This appeal for the Assessment Year (hereinafter, the AY ) 2013-14 filed by the Revenue is directed against the order dated 24.09.2019 passed by the Commissioner of Income Tax (Appeals)-30, New Delhi [hereinafter, the CIT (A) ]. 2. Following grounds are raised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... crutinized and the assessment was completed at loss of (-) Rs. 5,65,340/- under section 143(3) of the Income Tax Act,1961 (hereinafter the Act ). Based on the search and seizure operations on Shalimar Group of cases on 18.06.2015, the notice under section 153C of the Act was issued to the respondent/assessee. In response to notice under section 153C of the Act, the respondent/assessee filed its ITR declaring loss of (-) Rs. 19,98,293/- on 12.02.2018. The case was completed under section 153C of the Act wherein loans aggregating to Rs. 14,30,00,000/- were treated as unexplained and thus taxed under section 68 of the Act. Aggrieved, the respondent/assessee filed appeal before the Ld. CIT(A), who deleted the entire addition of Rs. 14,30,00,000 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... curities (P) Ltd. has built upon the cases of CIT vs. RRJ Securities Limited reported as 380 ITR 612 (Delhi) and M/s. AR Infra India Limited vs. ACIT reported as 394 ITR 569 (Delhi). I find that the seized documents referred to in the satisfaction notes cannot be said to be incriminating, with regard to this assessee for this assessment year. In this connection, reliance is also placed upon orders of Delhi High Court in the cases of - (i) CIT vs. Kabul Chawla, 380 ITR 573 (ii) Pr. CIT vs. Lata Jain, 384 ITR 543 (iii) CIT vs. Kurele Paper Mills P. Ltd., 380 ITR 571 (iv) CIT vs. Smt. Kusum Gupta, ITA No. 634/2015 I am bound by the wisdom of Hon'ble Supreme Court, as provided in the case of CIT vs. Singhad Technical Education Society (orde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We are therefore, of the considered view that the decision of the Hon ble Supreme Court in the case of Singhad Technical Education Society 397 ITR 344 and the decisions of the Hon ble jurisdictional High Court in the cases of RRJ Securities Ltd. and AR Infra India Ltd. 394 ITR 569 are applicable here in the present case. We, therefore, do not find any infirmity in the impugned order and thus, we decline to interfere with the finding of the Ld. CIT(A). Accordingly, the appeal of the Revenue is dismissed. 7. The issue raised by the Ld. Counsel has not been raised through Cross Objection, Cross Appeal or under Rule 27 of the ITAT Rules. We, therefore, do not find fit to decide this issue, being academic in nature. 8. In the result, the appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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