Case Law Details
Regency Mahavir Properties Vs ACIT (ITAT Mumbai)
It is an undisputed fact that the said documents P23 and P26 on the basis of which the Assessing Officer has made the addition in the case of the assessee were found during the course of the search conducted at the premises of Ashray Premises Pvt. Ltd. Since these documents have been found during the course of search conducted in the case of Ashray Premises Pvt. Ltd., if the Assessing Officer wanted to make addition, the assessment should have been completed in the case of the assessee only u/s. 153C r.w.s. 143(3). No assessment has been completed u/s. 153 r.w.s. 143(3) neither any satisfaction that these documents belong to the assessee was brought on record by the Assessing Officer of Ashray Premises Pvt. Ltd. Therefore, on this basis also the addition made in the case of the assessee cannot be sustained.
FULL TEXT OF THE ITAT JUDGMENT
Both these appeals have been filed by the assessee against the common order, dated 3012.2015, of the CIT(A), Pune, for assessment years 2007-08 and 2010-11.
2. The assessee has taken following effective grounds of appeal for A.Y. 2007-08:
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