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Assessee has raised the ground thatthe learned C.I.T.(A) has committed gross error in confirming the addition of Rs. 10,11,780.00 made by the learned A.O., under the head commission income, particularly when, the impugned addition was made on the basis of wrong facts and there was no such claim made by the Assessee in the return filed U/S.153C of the Act, hence not sustainable in the eye of law, as such the impugned addition is liable to be deleted in the interest of justice.

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Sec. 153C of Income Tax Act, 1961—Assessment—Assessee has not given any explanation regarding the nature of mistake and no document such as books of account or bank statement or cash flow-statement has been filed by the assessee, further, the proceedings u/s. 153C cannot be used by the assessee to reduce his income and if assessee wants to reduce his income, he has to file revised return of income- Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment - MUZIBUR RAHEMAN KHAN V/s ASSTT. CIT - [2020] 28 ITCD Online 011 (ITAT-CUTTACK)

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