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291 results for “section 68”+ Section 250(6)clear

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Key Topics

Addition to Income68Section 6858Section 250(6)37Section 25034Section 26334Section 143(3)33Section 142(1)33Section 153A33Section 13232Disallowance

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 753/CHANDI/2022[AY 2019-20]Status: DisposedITAT Chandigarh03 May 2024

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Deepak Anand, AdvocateFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 115BSection 133ASection 143(2)Section 143(3)Section 68Section 69Section 69A

250/- was brought to tax at normal rate and the amount of Rs. 69,66,000/- was brought to tax under section 115BBE of the Act. 4. Here it would be relevant to refer to the findings during the course of survey operation the show cause issued by the AO during the course of assessment proceedings and the submissions

Showing 1–20 of 291 · Page 1 of 15

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19
Cash Deposit16
Deduction11

M/S FAMINA KNIT FABS,LUDHIANA vs. ACIT, C-3, LUDHIANA

In the result, the appeal of the assessee in ITA

ITA 1494/CHANDI/2017[2014-15]Status: DisposedITAT Chandigarh28 Feb 2019AY 2014-15
For Appellant: Shri Hari Om Arora, AdvFor Respondent: Shri Ashish Gupta, CIT DR
Section 250(6)

250(6) of the Income Tax At, 1961 (hereinafter referred to as ‘Act’). 2. It was c o m m

SANJEEV KUMAR GOYAL,FATEHABAD vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assesse is allowed

ITA 80/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 143(2)Section 250(6)Section 253Section 68

250(6) of the Income Tax Act, 1961 which was dismissed. Therefore the present second appeal under section 253 of the Income Tax Act, 1961 before us against the aforesaid order dt. 20/01/2023 which is hereinafter referred to as the impugned order. FACTUAL MATRIX 3. The assessee for the aforesaid business of running a hotel has been maintaining

BANUR BROTHER ,PATIALA vs. ITO-WARD-1, AMBALA

In the result appeal of the assessee is allowed as and by way of remand to Ld

ITA 772/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh27 Jun 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Nikhil Goyal, Advocate &For Respondent: Shri Rohit Sharma, CIT DR
Section 142(1)Section 143(1)Section 143(2)Section 144Section 250Section 253Section 270ASection 69A

250 of the Act by relying on the Remand Report from the Ld. AO and submissions of the Assessee have not been considered in the impugned order. 5. That the impugned Order had been passed in gross violation of the principle of natural justice and without allowing reasonable opportunity of being heard to the Assessee. 6. That the Appellant craves

TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed

ITA 754/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh12 Jan 2024AY 2019-20

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Deepak Anand, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 133Section 133ASection 143(3)Section 14jSection 68Section 69

6. That the appellant, craves leave to add or amend any ground of appeal before appeal is heard or dispose off. 3. During the course of hearing the Ld. AR submitted that the survey operation u/s 133A was conducted on the business premises of appellant on 16/04/2018. During the course of survey, the appellant surrendered the amount

RAJIV KUMAR GOYAL,DHURI vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assessee is allowed

ITA 79/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By Order Of The Ld. Cit(A) Dated 03/02/2023 In Appeal No. 10850/2018-19/It/Cit(A)-5/Ldh/2021-22 For A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 03/02/2023 Which Is Hereiafter Referred To As The Impugned Order. Factual Matrix 3. The Assessee Had For The Relevant Year I.E; A.Y. 2019-20 Was Also Engaged In The Same Business I.E; Manufacturing Of Pvc Pipes & Had Filed

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. D.R
Section 133ASection 139(1)Section 250(6)Section 253

250(6) of the Income Tax Act, 1961 which was dismissed. Therefore the present second appeal under section 253 of the Income Tax Act, 1961 before us against the aforesaid order dt. 03/02/2023 which is hereiafter referred to as the impugned order. Factual Matrix 3. The assessee had for the relevant year i.e; A.Y. 2019-20 was also engaged

AARTI SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

In the result, all the above appeals are allowed

ITA 1145/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh13 Mar 2026AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT Central Circle-1 Chandigarh 4, Amritashergil Marg, New Delhi- 110003 स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT Central Circle-1 Chandigarh 53, Jor Bagh, New Delhi-110003 स

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal, C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 10(38)Section 132Section 132(4)Section 250(6)Section 68Section 69C

250(6) of the Income Tax Act, 1961 by the Learned Commissioner of Income Tax (Appeals)-3,Gurgaon is against law and facts on the file in as much as he was not justified to uphold the action of the Learned Assessing Officer in making an addition of Rs. 28,30,02,558/-representing sale proceeds of equity shares held

ANIKET SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

In the result, all the above appeals are allowed

ITA 1146/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh13 Mar 2026AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT 4, Amritashergil Marg, New Delhi- 110003 Central Circle-1 Chandigarh स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT 53, Jor Bagh, New Delhi-110003 Central Circle-1 Chandigarh स

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal, C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 10(38)Section 132Section 132(4)Section 250(6)Section 68Section 69C

250(6) of the Income Tax Act, 1961 by the Learned Commissioner of Income Tax (Appeals)-3,Gurgaon is against law and facts on the file in as much as he was not justified to uphold the action of the Learned Assessing Officer in making an addition of Rs. 28,30,02,558/-representing sale proceeds of equity shares held

SHRI HARISH SHARMA,LUDHIANA vs. ITO , LUDHIANA

In the result, the appeal of the assessee is allowed

ITA 327/CHANDI/2020[2017-18]Status: DisposedITAT Chandigarh11 May 2021AY 2017-18
For Appellant: Shri Ashwani Kumar, CAFor Respondent: Ms.Laganpreet Sidhu, Addl. CIT
Section 115BSection 133ASection 143(3)Section 250(6)Section 68

250(6)) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’, for the assessment year 2017-18, whereby the Ld. CIT(A) has dismissed the appeal A.Y .2017-18 Page 2 of 9 filed by the assessee against the assessment order passed u/s 143(3) of the Act. 2. The brief facts of the case are that

M/S VIRTUOSO NETSOFT PVT. LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed

ITA 1326/CHANDI/2019[2013-14]Status: DisposedITAT Chandigarh02 Mar 2021AY 2013-14
For Appellant: Shri Shri Jaspal Sharma, AdvocateFor Respondent: Shri Ashok Khanna, Addl. CIT
Section 68

6. It is a matter of fact that the same was confronted to the assessee vide order sheet entry dated 27.01.2016 which reads as under: '2. You have produced dissolution deed of M/s Vastech Solutions as per which the firm was dissolved on 20.01.2011. However, you are showing loan from M/s Vastech Solutions standing as on 31.03.2012 amounting to Rs.25

SHRI BHUWAN GOYAL,LUDHIANA vs. DCIT, CC-1, LUDHIANA

In the result, appeal of the assessee is allowed

ITA 1385/CHANDI/2019[2017-18]Status: DisposedITAT Chandigarh25 Sept 2020AY 2017-18
For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Arvind Sudarshan, JCIT
Section 115BSection 132Section 132(4)Section 153ASection 250(6)Section 69

250(6) of the Income Tax Act, 1961 by the Ld. Commissioner of Income Tax(Appeals)-5, Ludhiana is against law and facts on the file in as much as he was not justified to arbitrarily uphold the action of the Ld. Assessing Officer in treating the sum of Rs. 1.00 crore out of total surrender made

SWARN GANGA JEWELLERS,CHANDIGARH vs. DCIT, CIRCLE 4(1) NOW DCIT, CIRCLE 1(1), CHANDIGARH

In the result, the appeal of the assessee stands allowed

ITA 675/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh28 Jun 2024AY 2017-18

Bench: This Tribunal Being Aggrieved By An Order No. Itba/Nfac/S/250/2022-23/1045180258(1) For A.Y. 2017-18 Dt. 05/09/2022 Which Is Hereinafter Referred To As The “Impugned Order”. The Impugned Order Is Passed By Cit(A) In Terms Of Section 250 Of The Income Tax Act, 1961. Factual Matrix 2. That Survey U/S 133A Of The Income Tax Act, 1961 Was Conducted On The Business Premises Of The Assessee On 06/09/2016. The Assessee Surrendered A Sum Of Rs. 50,00,000/- During The Survey & Paid Tax Thereon. The Return Of Income Was Filed On 01/11/2017 Declaring A Total Income Of Rs. 89,48,260/-. Thereafter The Case Of The Assessee Was Selected For Scrutiny Under Compulsory Scrutiny Guidelines & Notice Under Section 143(2) Of The Act Was Issued On 11/09/2018. The Assessment Was Finalised Vide Order Dt. 23/12/2019 Whereby Addition Of Rs. 95,70,882/- Was Made U/S 68 R.W..S 115Bbe Of The Act.

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 133ASection 143(2)Section 250Section 253Section 68

68 r.w.s 115BBE of the Act. 16. The assessee being aggrieved by the impugned order of CIT(A) has raised following grounds of appeal in view of above factual matrix: 1. That on facts, circumstances and legal position of the case, the Worthy CIT(A), NFAC has erred in passing the order in contravention of provisions of S. 250(6

SH. RAJNEESH THAKUR,LUDHIANA vs. ACIT, C-VII, LUDHIANA

The appeal is allowed

ITA 1565/CHANDI/2018[2011-12]Status: DisposedITAT Chandigarh23 Dec 2020AY 2011-12

Bench: Smt. Diva Singh & Smt.Annapurna Guptaआयकरअपीलसं./Ita No.1565/Chd/2018 िनधा"रणवष"/ Assessment Year : 2011-12

For Appellant: ShriSudhirSehgal, AdvocateFor Respondent: ShriAtulJayaswal, Sr. Dr
Section 250(6)Section 69Section 69A

250(6)of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’). 2. Ground no. 1& 2, it was pointed out by the Ld.Counsel for the assessee, related to the same issue of addition made under 69A of the Act on account of alleged unexplained cash deposits in bank amounting to Rs. 16,49,000/-,and the grounds

AMAN THUKRAL,LUDHIANA vs. INCOME TAX OFFICER WARD 2(1), LUDHIANA , LUDHIANA

Accordingly, Additional Ground No. 1 is allowed for statistical

ITA 886/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh11 Mar 2026AY 2021-22

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Sh. Pankaj Bhalla, CAFor Respondent: Sh. Manav Mangal, CIT DR
Section 143(3)Section 144BSection 250(6)Section 69C

250(6) of the Act. It was submitted that the Ld. CIT(A) has merely reproduced the findings of the Assessing Officer and the submissions of the assessee without recording independent findings or giving proper reasons for confirming the additions. It was contended that the first appellate authority is required to pass a speaking order stating the points for determination

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

ITA 140/CHANDI/2020[2014-15]Status: DisposedITAT Chandigarh18 Nov 2024AY 2014-15

Bench: Ao)

For Appellant: Sh.Tejmohan Singh, Adv. and Sh. Vineet Khurana, C. AFor Respondent: Sh.Vivek Vardhan, JCIT, Sr. D. R
Section 142(1)Section 143(2)Section 253

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

ITA 141/CHANDI/2020[2015-16]Status: DisposedITAT Chandigarh18 Nov 2024AY 2015-16

Bench: Ao)

For Appellant: Sh.Tejmohan Singh, Adv. and Sh. Vineet Khurana, C. AFor Respondent: Sh.Vivek Vardhan, JCIT, Sr. D. R
Section 142(1)Section 143(2)Section 253

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

ITA 142/CHANDI/2020[2016-17]Status: DisposedITAT Chandigarh18 Nov 2024AY 2016-17

Bench: Ao)

For Appellant: Sh.Tejmohan Singh, Adv. and Sh. Vineet Khurana, C. AFor Respondent: Sh.Vivek Vardhan, JCIT, Sr. D. R
Section 142(1)Section 143(2)Section 253

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

ITA 139/CHANDI/2020[2012-13]Status: DisposedITAT Chandigarh18 Nov 2024AY 2012-13

Bench: Ao)

For Appellant: Sh.Tejmohan Singh, Adv. and Sh. Vineet Khurana, C. AFor Respondent: Sh.Vivek Vardhan, JCIT, Sr. D. R
Section 142(1)Section 143(2)Section 253

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate

M/S SINGLA BUILDERS AND PROMOTERS LIMITED,RUPNAGAR, PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

ITA 487/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh06 Feb 2026AY 2013-14

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

For Appellant: Sh. Parikshit Aggarwal (CA) & Smt. ShrutiFor Respondent: Smt. Kusum Bansal (CIT) & Shri Rajat Kumar
Section 127Section 132Section 142ASection 143(3)Section 153ASection 153BSection 69ASection 69B

250 of the Income Tax Act, 1961 hereinafter referred to as "Act"). 2. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of passing asst. order by illegally assumingjurisdiction u/s 153A and more-so when no incriminating material qua this year was found in search

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

ITA 482/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh06 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

For Appellant: Sh. Parikshit Aggarwal (CA) & Smt. ShrutiFor Respondent: Smt. Kusum Bansal (CIT) & Shri Rajat Kumar
Section 127Section 132Section 142ASection 143(3)Section 153ASection 153BSection 69ASection 69B

250 of the Income Tax Act, 1961 hereinafter referred to as "Act"). 2. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of passing asst. order by illegally assumingjurisdiction u/s 153A and more-so when no incriminating material qua this year was found in search