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TMI Blog2025 (3) TMI 1467X X X X Extracts X X X X X X X X Extracts X X X X ..... partment : Sh. Sunil Yadav, CIT(DR) ORDER PER SATBEER SINGH GODARA, JM These twin assesses Smt. Bharti Sharma and Sh. Pankaj Sharma have filed their instant as may appeals ITA Nos. 898/Del/2024 and 939/Del/2024 for assessment year 2021-22, against the Commissioner of Income Tax (Appeals)-30 [in short, the "CIT(A)"], New Delhi's orders dated 31.01.2024 and 05.02.2024 passed in case nos. 10099/20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Co. Ltd. vs. CIT (1998) 229 ITR 383 (SC) having settled the issue long-back that the tribunal could indeed admit the additional ground in section 254 appellate proceedings in order to determine the correct tax liability of an assessee provided all the relevant facts duly form part of the records. We make it clear that since we are dealing with the above limited legal issue of validity of the impu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is in view of the said receipts that the learned Assessing Officer framed his twin assessments herein dated 29.12.2022 under section 143(3) of the Act making the corresponding on-money payments and other additions, as the case may be in these assesses hands which stand upheld in the lower appellate proceedings. 5. It is in this factual backdrop that there arises the first and foremost legal issu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer having jurisdiction....." Hon'ble jurisdictional high court's recent various landmark decisions, CIT-7 Vs. RRJ Securities Ltd. (2016) 380 ITR 612 (Del), PCIT Vs. Ojjus Medicare (P) Ltd., (2024) 465 ITR 101 (Del) and CIT Vs. Jasjit Singh (2024) 465 ITR 101 (SC) have already settled the issue that the reference in such an instance u/s 153C is the date when the Assessing Officer re ..... X X X X Extracts X X X X X X X X Extracts X X X X
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