9911796707
TMI Blog2025 (3) TMI 1382X X X X Extracts X X X X X X X X Extracts X X X X ..... he action of Ld. AO in assuming jurisdiction u/s 153C and passing the impugned order is bad in law and void-ab-initio and that too when the jurisdictional conditions under section 153C of the Act were not met. 2) That in any case and in any view of the matter, the assessment framed under section 153C of the Act, is bad in law and against the facts and circumstances of the case. 3) That having regard to the facts and circumstances of the case CIT (A) has erred in law and on facts in confirming the action of the Ld. A.O. in making an addition of Rs. 65,57,300/- u/s 68 of the Act, vide para 6 of the assessment order and more so when there was no incriminating material found as a result of search and that too without proper appreciation of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... without observing the principle of natural justice. 9) That the appellant craves the leave to add, alter or amend the grounds of appeal at any stage and all the grounds are without prejudice to each other. 2. Brief facts of the case are that a search and seizure operation u/s 132 was conducted on 27.11.2014 in the case of Maconns, Meenu and Yadav Singh Group wherein certain incriminating documents were found & seized relating to the assessee. Thereafter, notice u/s 153C was issued on 27.06.2016. In response, assessee filed its return showing income of Rs. 4,57,650/-. Subsequently, notices u/s 143(2) and 142(1) were issued and AO completed assessment by making addition of Rs. 65,57,300/-on account of unexplained investment in immoveable p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded that addition on account of share application money and interest on unsecured loan is not being dehors the seized material found at the time of search. As regards property deed found is concerned, Ld. Counsel for the assessee submitted that the same was relating to building of the assessee which was also duly reflected in the balance sheet. 5. Per contra, Ld. DR could not controvert the submissions of the assessee. 6. Upon careful consideration, we find that in this case addition has been made on account of share application and unsecured loan interest relating to purchase of property. All these items were duly disclosed by the assessee in the balance sheet, hence, the submission of the ld. Counsel for the assessee is correct as no se ..... X X X X Extracts X X X X X X X X Extracts X X X X
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