ORDER

Per Bench:

The present appeal by the Revenue and the cross objection by the assessee has been filed against the order of ld. CIT(A)-XXVII, New Delhi dated 30.01.2015.

2. Following grounds have been raised by the Revenue:

“1. The ld. CIT(A) has erred in law as well as on facts in holding that there is merit in the contention of the appellant regarding unlawful initiation of proceedings u/s 153C of the Income Tax Act, 1961.

2. The Ld. Commissioner of Income Tax (Appeals) has erred in law as well as on facts in holding that assessee company is not resident in terms of provisions under section 6(3)(ii) of the I.T. Act for the purpose of tax liability whereas on the basis of seized documents/e-mails and various statements of Sh. Ajay Kalsi/Sh. Anil Aggarwal, it has been established that control and management of the assessee company is situated wholly in India.

3. The Ld. Commissioner of Income Tax (Appeals) has erred in law as well as on facts in ignoring that underlying assets and sources of revenue of all the overseas companies are the Indian Companies.

4. The Ld. Commissioner of Income Tax (Appeals) has erred in law as well as on facts in ignoring the substantial evidence in form of