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ITA Nos. 247 -C-2021 & CO 28-C-2021, M/s Agya Ram ManoharLal, Khanna, 18 could be made in the hands of assessee firm u/s 69 as unaccounted investment during assessment year under consideration. The ground raised by the department is dismissed.
0 In the result, the appeal of the department stands dismissed.
0 In the CO, the assessee has challenged the assumption of juri iction on the ground that notice u/s 153A could not have been issued in a case covered by survey u/s 133A of the Act and secondly the assessment was bad in law as the approval obtained u/s 153D of the Act was a mere mechanical approval. However, we have already dismissed the appeal of the Department on merits and therefore, at this juncture, we are not inclined to comment/adjudicate on the assumption of juri iction by the AO u/s 153A and on issue of approval obtained u/s 153D of the Act and we treat the CO as in fructuous and dismiss it as such.
0 In the final result, both the appeal of the Department as well as the CO of the assessee stand dismissed. Order pronounced on 22.04.2022. ( N.K. SAINI) Judicial Member Dated : 22.04.2022 “आर.के.” आदेशक"""त"ल"पअ"े"षत/ Copy of the order forwarded to : 1. अपीलाथ"/ The Appellant
""यथ"/ The Respondent 3. आयकरआयु"त/ CIT 4. आयकरआयु"त (अपील)/ The CIT(A)
"वभागीय""त"न"ध, आयकरअपील!यआ"धकरण, च$डीगढ़/ DR, ITAT, CHANDIGARH 6. गाड'फाईल/ Guard File आदेशानुसार/ By order, सहायकपंजीकार/