ORAL JUDGEMENT

(PER: HON'BLE MR JUSTICE KRISHNA S DIXIT)

This Appeal by the Revenue calls in question the order dated 19.04.2022 whereby the Income Tax Appellate Tribunal has negatived Revenue’s Appeal in ITA No.494-497/BANG/2021 and thereby, has affirmed common order dated 31.03.2021 for the Assessment Years

2011-12, 2012-13, 2013-14, 2014-15 & 2015-16.

2. The Revenue has framed the following substantial questions of law:

“1. Whether, on the facts and in the circumstances of the case and law, the Tribunal is right in law in deleting the additions made by assessing authority by holding that there are no incriminating materials on which additions are made ignoring that the incriminating materials were found against assessee in search conducted in case of M/s. Srinivasa Trust, KBD Sugars & Distilleries which were seized and subsequently satisfaction was recorded on 14/09.2018 in pursuance to the provisions of Section 153C of the Act.

2. Whether, on the facts and in the circumstances of the case and law, Tribunal and CIT(A)’s orders can be said as perverse in holding that additions made by assessing authority cannot be sustained in law ignoring mandate of sections

153 A and 153C of the Act