Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No. 63 & 64/Srt/2023 (Ay: 2016-17 & 2019-20) (Physical Hearing) D.C.I.T., Shree Kuberji Textile Deck, Central Circle-4, 2Nd Floor, Shree Kuberji Corporate Vs. Surat. House, Begumpura, Nr. Khndaa Kuva Road, Surat-395002. Pan No. Acsfs 4939 A Appellant/ Revenue Respondent/ Assessee D.C.I.T., Shree Kuberji Textile Deck, Central Circle-4, 2Nd Floor, Shree Kuberji Corporate Vs. Surat. House, Begumpura, Nr. Khndaa Kuva Road, Surat-395002. Pan No. Acsfs 4939 A Appellant/Revenue Respondent/Assessee
section 69B based on MoU seized during the search action. 13. Brief facts of the case are that during the search on 06/02/2020, besides other document, a copy of MOU signed by Jitubhai Harjibhai Desai (benami Aai Jai Creations Pvt Ltd) and Naresh Agarwal dated 29/06/2018 was found. During the assessment, the Assessing Officer referred the contents of such