ABCI INFRASTRUCTURES PRIVATE LIMITED,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI
In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed
ITA 40/GTY/2022[2013-14]Status: HeardITAT Guwahati03 Apr 2023AY 2013-14
Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad
For Appellant: (1) That on the facts and in the circumstances of the case
Section 143(3)Section 147Section 148Section 153Section 153C
reassessment is not discernable from the finding. Therefore, the order of the ld.
CIT(Appeals) justifying the additions computed at 6% of the contract receipt is not sustainable. In view of the above discussion, we summarize the result as under:-
(a) Section 153A starts with an non-obstante clause, i.e. notwithstanding. Hence once a search has been conducted upon
