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Ground raised by the assessee is thatthe ld. CIT(A) has erred on facts and in law in deciding the appeal without admitting the additional evidence filed under rule 46A.

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Sec. 147 & 148 of Income Tax act, 1961—Reassessment— If the conditions as stipulated u/s 153C r.w.s. 153A are not satisfied then the AO can invoke the provisions of Section 147/148 - AO has stated in the reasons recorded that documents were seized and forwarded by the AO of the searched person, accordingly, there was no error or illegality in the initiation of proceedings u/s 147/148 - SURESH KUMAR SHARMA V/s ITO - [2020] 81 ITR (TRIB) 001 (ITAT-JAIPUR)