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Whether in the facts and circumstances of thecasethe finding of the Tribunal is perverse, holding that Rs. 22,40,000/- is the income of the appellant, without appreciating evidence on record, that the loose paper was not found from the possession of the appellant and Section 292C of the Act is not attracted, the addition of Rs. 22,40,000/- as income in the hands of the assessee?

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Sec. 153A of Income Tax Act, 1961— Assessment — No reason has been recorded by the AO with regard to the loose papers being of the assessee and therefore, the AO could not have assumed the jurisdiction in terms of Section 153C- The residential premises of the assessee were also searched together with the group Concerns in which assessee had interest as partner therein, thus, Section 153A was attracted and accordingly, assessment under Section 153A read with Section 143(3) had been framed and since the search had taken place at the residence of the assessee as well, thus, no proceedings for framing assessment under Section 153C arose. - RAJEEV MUJUMDAR V/s CIT - [2020] 426 ITR 559 (MP)