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TMI Blog2025 (5) TMI 1543X X X X Extracts X X X X X X X X Extracts X X X X ..... Condonation of delay: 2. On perusal of the case records, it is noticed that the captioned appeals filed by the assessee are barred by limitation on account of delay in filing of appeal No. ITA No. 452/RPR/2024 by 11 days and Appeal No. ITA 519/RPR/2024 by 36 days, as pointed out by the registry. To remove this defect the assessee had furnished the applications for condonation of delay along with affidavit to explain the sufficient cause on account of which the delay was occasioned. 3. On a thoughtful consideration of the facts and reasons for delay as explained in the condonation petition by the assessee, which are confronted to the other side i.e., Ld. CIT-DR. On perusal of the same, we find substance in the request of the assessee that the delay was on account of justifiable reasons, we find it appropriate to condone the delay of 11 and 36 days involved in the aforesaid appeals, accordingly, the delay in filing of aforesaid appeals are condoned. 4. All the aforesaid appeals pertain to a single assessee having interconnected, identical and interlinked issues, therefore, all these appeals are being heard together and are being disposed of under this common order. 5. ITA No. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... with properly on the merits, moreover the legal ground raised by the assessee challenging the validity of reopening of the assessment u/s 147 r.w.s 148 of the Act for which all the relevant facts and details are available on the assessment records. The issues were decided only on the basis of absence of assessee, stating that the appellant is not interested in perusing the appeal, such observations of the Ld. CIT(A) could not be considered to be judicious, just and proper in the eyes of law, whereas the reopening in the case of assessee was totally against the mandate of law, which can be gathered from the documents / evidence like reasons to believe, approval u/s 151 etc., therefore, the assessment framed was to be quashed. 6.3 Per contra, Shri S. L. Anuragi, Ld. CIT-DR representing the revenue submitted that assessee had adopted evasive approach before the Ld. CIT(A) to prolong the litigation. Under such circumstances, Ld. CIT(A) had rightly appreciated the issue on the basis of facts available with him and in absence of any contention raised by the assessee qua the issue before him, he was constrained to pass the order, therefore, the order of Ld. CIT(A) cannot be held to be un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o consider and decide any issue arising in the proceedings before him in appeal filed for its consideration, even if the issue is not raised by the appellant in its appeal before the CIT(A). Thus once an assessee files an appeal under Section 246A of the Act, it is not open to him as of right to withdraw or not press the appeal. In fact the CIT(A) is obliged to dispose of the appeal on merits. In fact with effect from 1st June, 2001 the power of the CIT(A) to set aside the order of the Assessing Officer and restore it to the Assessing Officer for passing a fresh order stands withdrawn. Therefore, it would be noticed that the powers of the CIT(A) is co-terminus with that of the Assessing Officer i.e. he can do all that Assessing Officer could do. Therefore, just as it is not open to the Assessing Officer to not complete the assessment by allowing the assessee to withdraw its return of income, it is not open to the assessee in appeal to withdraw and/or the CIT(A) to dismiss the appeal on account of nonprosecution of the appeal by the assessee. This is amply dear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... osed sales, thereby, wrongly confirming the addition of Rs. 36,43,972/- over and above the declared G.P. of Rs. 21,83,330/- in the return filed u/s 153A. 5. (a) For that on the facts and in the circumstances of the case, the Ld. CIT(A) grossly erred in confirming the addition of Rs. 4,83,47,607/- made by the A.O. on account of addition made in the earlier assessment framed u/s 144 r.w. section 147 even when the assessee company has filed an appeal which was pending at the time of assessment proceedings. (b) For that, Ld. CIT(A) failed to appreciate that the aforesaid addition of Rs. 4,83,47,607/- amounted to double addition, which is not permissible in the eyes of law. 6. For that the Ld. CIT(A) ought to have directed the A.O. to compute proper interest u/s 234A, 234B and 234C as per law. 7. The appellant craves leave to add further grounds of appeal or alter the grounds at the time of hearing. 8.1 The additional grounds of appeal raised by the assessee vide application dated 12.12.2024: 1. For that the A.O. was not justified in passing a consolidated / common order for A.Y: 2011-2012 to 2019-2020 in violation of the mandate of sec. 153D of the Act, thereby, vitiatin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the assessee in IT(SS)A No. 12/RPR/2024 for AY 2011-12, challenging the validity of approval granted u/s 153D, being the same has been passed under a consolidated / common order for AY 2011-12 to 2019-20. The dispute raised based on such contention was that assessment framed, or demand raised for the instant year is vitiated in law and is nullity for want of prior approval of the approving authority, as the approval granted in a manner which is not inconsonance with the law. 8.4 The aforesaid issue raised under the additional ground has been discussed and decided by us in assessee's own case in IT(SS)A No. 14 & Anors/RPR/2024 vide our order dated 16.01.2025. Our observations and findings therein are extracted hereunder for the sake of convenience and reference: 14 Additional Ground No. 1: Challenging the validity of consolidated / common order for AY 2011-12 to 2019-20 in violation of mandate of section 153D of the Act. 14.1 On this issue, as per the application for admission of additional ground, the contention raised by the assessee was that the consolidated approval granted under section 153D is not in the manner in consonance with the law. It is contended that the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT-DR, the issue raised under additional ground was also covered by certain legal grounds by the assessee, therefore, those are dealt with separately, whereas the issue in present case has been decided by the coordinate bench of ITAT, Raipur in a recent decision in the case of Panchsheel Solvent Pvt. Ltd., Rajnandgaon Vs. ACIT, Central-2, Raipur in ITA no. 2,3,4,5 & 6 /RPR/2024 dated 26.12.2024, wherein the findings of Tribunal are as under: 7.4 Regarding additional ground no. 1 & 2 in ITA No. 5/RPR/2024 for AY 2013-14, raised by the assessee challenging the validity of assessment order passed u/s 153A r.w.s. 143(3) and approval u/s 153D, stating that the order of assessment and approval are granted under a combined / consolidated order and combined / common approval is not in accordance with the mandate of law prescribed under the impugned sections of the Act. We do not find any substance in the contentions raised by the assessee, as the issue is covered by the observations of Hon'ble Jurisdictional High Court in the case of Hitesh Golecha Vs. ACIT, Central Circle-1, Raipur, TAXC No.76/2024, dated 10.04.2024. 7.5 The Hon'ble High Court in its aforesaid order, after deliberat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... supported by the principle laid down by Hon'ble Jurisdictional HC, vide judgment in the case of Hitesh Golecha vs. ACIT, Central Circle-1, Raipur, TAXC No.76/2024, dated 10.04.2024, therefore, we are inclined to follow a view adopted by us, which in absence of any further clarification or any decision contrary to the aforesaid decision by any higher forum i.e., by the Hon'ble Apex Court, cannot be deviated. Under such circumstances, we do not find any substance in the additional ground raised by the assessee, thus, we dismiss the same. 8.5 Considering the aforesaid view adopted by us, as the facts and circumstances inter alia the issue in present case are identical, common and interlinked, with no further advancement of information or explanations on behalf of the assessee, thus, our findings and observation therein, on the issue are squarely covers the controversy raised through impugned additional ground, in the present case, accordingly, the view adopted by us in ITA no. 513/RPR/2024 shall apply mutatis mutandis in appeal No. IT(SS)A No. 12/RPR/2024, also. Resultantly, the additional ground raised by Ld. AR, on behalf of the assessee, stands dismissed. 8.6 Regarding Ground o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pital received amounting to Rs.1.81 Cr had not been assessed relating to A.Y 2013-14. Sir In A.Y 2013-14, unaccounted income had been duly declared by the assessee amount to Rs. Sir the income declared is the source and the share capital received is the application in relation to the same. Addition of both source and application will lead to double taxation for the assessee. Sir it is request to kindly not add the same since it will led to double taxation and will not implement justice for the assessee." 4.18. The contention of the assessee company ls considered and accepted. After careful examination of the documents/loose papers found and seized from the various premises, statement recorded during the search and seizure proceedings and post search investigation and considering the replies filed by the assessee during the assessment proceedings is amply clear that the assessee ls the ultimate beneficiary of the amounts received from Kolkata base paper and shell companies in the form of share capital, share premium, share application money and unsecured loan. 4.19. "Cash credits. 68. Where any sum is found credited in the books of an assessee maintained for any previous ye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or all the sums credited in the books of account of the company irrespective of the nomenclature or the source indicated by the assessee. The Assessing Officer is empowered to lift the corporate veil and examine the real nature of the transaction. It is for the assessee to prove and establish the identity of the investors. their creditworthiness and the genuineness of the transaction which is a principal ingredient. Apart from identification of the shareholders, there should be creditworthiness and also genuineness of the transaction. The furnishing of material is not sufficient. It is not necessary for the Assessing Officer to locate the exact source of the credits. The onus lies on the assessee to offer an explanation to the satisfaction of the Assessing Officer about the nature and sources of such sums so credited. In the case of A. Govindarajulu Mudaliar 34 ITR 807 (SC), the SC held that where the assessee failed to prove satisfactorily the source and nature of credit entry in his books, and it is held that the relevant amount is the income of the assessee, it is not necessary for the department to locate its exact source. Further in the case of McDowell & Co. ltd., has c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by a party and rely on those recitals. If all that an assessee who wants to evade tax is to have some recitals made in a document either executed by him or executed in his favour then the door will be left wide open to evade tax. A little probing was sufficient in t e present case to show that the apparent was not the real. The taxing authorities were not required to put on blinkers while looking at the documents produced before them. They were entitled to look into the surrounding circumstances to find out the reality of the recitals made in those documents." There are several judgments of the High Court which have clearly laid down the principle that the onus lay with the assessee in section 68 of the Act. The word "identity" was meant to be the condition or fact of a person or thing being that specified unique person or thing. The identification of the person would include the place of work, the fact that it was actually carrying on business and recognition of the said company fn the eyes of public. Merely producing PAN number or assessment particulars did not establish the identity of the person. The actual and true identity of the person or a company was the business und ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f N Tarika Properties Investment (P) Ltd (2013) 40 taxmann.com 525 (Delhi HC), the HC held that "We have heard the Id counsel for the parties. We are of the considered opinion that the orders of the CIT(A) and the ITAT in deleting the additions made by the AO u/s 68 are perverse and are clearly unsustainable." The Delhi High Court In the case of Commissioner of Income-tax v. Nipun Builders and Developers Pvt. Ltd. (350 /TR 407) had confirmed the addition on account of unexplained share application money u/s 68 and had observed on the issue of establishing the creditworthiness of the shareholders by the assessee as under: "That though the difficulty that may be faced by an assessee to unimpeachably establish the creditworthiness of the share applicants, mere furnishing of the copies of the bank accounts of the applicants was not sufficient to prove their creditworthiness. There must be some positive evidence to show the nature and source of the resources of the share applicant himself and, therefore, it was necessary for him to come before the Assessing Officer and confirm his sources from which he subscribed to the capital." Hon'ble Delhi High Court in a latter decision ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ts to the Department. Merely establishing the identity of the creditor is not sufficient. This is the ratio in a large number of decisions including: * Shankar Industries vs CIT (1978) 114 ITR 689(Cal); * C. Kant & Co vs CIT (1980) 126 ITR 63 (Cal); * Prakash Textile Agency vs CIT (1980) 121 ITR 890(Cal); * Oriental Wire Industries P. ltd vs CIT (1981) 131 ITR 688(Cal); * CIT vs United Commercial & industries Co.(P) Ltd., (1991) 187 ITR 596, 599(Cal) * M.A UnneeriKutti vs CIT (1992) 198 ITR 147, 150(Ker), Special Leave Petition dismissed by the Supreme Court (1993) 201 ITR (St.) 23 (SC); * CIT vs Precision Finance Pvt Ltd (1994) 208 ITR 465, 470(Cal) The manner of payment by the account payee cheque is also not sacrosanct and this cannot make a bogus transaction as genuine one: * CIT vs Precision Finance Pvt Ltd 208 ITR 465, 470, 471(Cal) * Cf. Nizam Wool Agency vs CIT (1992) 193 ITR 318, 320(AII). The below mentioned quote is the observation of H.on'ble Justice B.N. Kripal while delivering the judgment in the case of CIT vs. Divine Leasing 299 ITR 268 Delhi. The pernicious practice referred to by justice Kripal, of late has acquired such enormou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re application money and unsecured loan, it follows that the identity, creditworthiness or genuineness of the transaction is not established by merely showing that the transaction was through banking channels or by account payee instrument. It would be incorrect to state that the onus to prove the genuineness of the transaction and creditworthiness of the creditor stands discharged in all cases if payment is made through banking channels. Certificate of incorporation of company, payment by banking channel, etc. cannot in all cases tantamount to satisfactory discharge of onus. It has been elaborately established in the preceding paras that the assessee had failed to discharge its onus in proving the identity, creditworthiness and genuineness of the share applicants and hence the share application money/share capital/Share Premium and, unsecured loans introduced by Kolkata based paper shell companies credited in its books are treated as unaccounted income u/s 68 of the Act. The year wise details of unaccounted income are as under: SI. No. F.Y A.Y Share capita/ share premium amount received Total undisclosed Income 1 2010-11 2011-12 3,25,00,000 3,25,00,000 2 2011-12 2012- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee instrument. It would be incorrect to state that the onus to prove the genuineness of the transaction and creditworthiness of the creditor stands discharged in all cashes if payment is made through banking channels. Certificated of incorporation of company, payment by banking channel, etc, cannot in all cases tantamount to satisfactory discharge of onus. It has been elaborately established in the preceding paras that the assessee had failed to discharge its onus in proving the identity, creditworthiness and genuineness of the share applicants and hence the share application money/share capital/ share premium and unsecured loans introduced by Kolkata based paper shell companies. In view of these facts, the appeal of the appellant deserves to be dismissed as it cannot be kept pending adjudication for indefinite period. It is the duty of the appellant to make necessary arrangements for effective representation on the appointed date. Mere filing of an appeal is not enough, rather it requires effective hearing also. Therefore, the appeal is found liable for dismissal. This view is supported by the following judicial pronouncements:- (i) In the case of Estate of Late Tukojirao Ho/ka ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed in assessing the total income of the appellant as discussed above. when repeated opportunity in this regard was provided clearly shows that the appellant is not interested in pursuing the appeal. In these circumstances, I have no option but to confirm the addition made by the Ld. AO and dismiss the grounds of appeal of the appellant. Respectfully, following the view taken in the case cited above, the appeal filed by the appellant deserves to be dismissed. Therefore, appeal on these grounds are dismissed. 8.10 Before us, Shri Subhash Agrawal, Adv., representing the assessee (in short, Ld. AR"), submitted that an amount of Rs. 3,27,00,000/- was already added to the income of the assessee in the original assessment u/s 144 r.w.s. 147 dated 19.12.2018 for the AY 2011-12 by ITO, Ward-2(1), Raipur, as evident from the observations of Ld. AO, while making the aforesaid addition, the same cannot be made again, otherwise the same would constitute taxing the same income twice. Ld. AR drew our attention to para 4.17 (page of the Assessment order (extracted supra), wherein assessee had clearly submitted before Ld. AO that "the above share capital have been duly added in the order passed u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ditions. The contention by Ld. AR that such unexplained investments received by the assessee are declared by the assessee, which was raised before Ld. AO and such contentions are noted at para 4.17, cannot be accepted in totality as nothing corroborative could be brought on record to support such claim, at the same time there was no whisper in the assessment order dealing with and dislodging such contentions, further, Ld. CIT(A) also had not commented on such claim of the assessee emerging from the assessment order, therefore, in all fairness the controversy raised in ground no. 3(b) in the assessee's appeal qualifies to be restore back to the file of Ld. CIT(A) for fresh adjudication. Needless to say, the assessee shall be afforded with reasonable opportunities of being heard in the set aside appellate proceedings in accordance with law. In result, Ground No. 3(b) of the assesse's appeal is partly allowed for statistical purposes. 8.13 Ground No. 4: Regarding confirmation of addition of Rs. 36,43,972/- made by the Ld. AO on account of unaccounted income of the assessee by estimating the Gross Profit of the assessee at 8% of the unaccounted sales. 8.14 The aforesaid issue raised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income of the appellant as discussed above, when repeated opportunity in this regard was provided clearly shows that the appellant is not interested in pursuing the appeal. In this circumstance, I have no option but to confirm the addition made by the Ld. AO and dismissed the grounds of appeal of appellant." 16.3 Aggrieved with the aforesaid decision with the Ld. CIT(A), assessee preferred an appeal before this tribunal, which is under consideration before us. 16.4 Ld. CIT-DR, on the issue of addition by the Ld. AO by estimating the profit on unaccounted sale @8%, had submitted that the assessee remains non-responsive before the First Appellate Authority, as also before the Tribunal during the proceedings in the present case. It seems that the assessee has no plausible explanation as to why the estimation of profit on unaccounted sale should not be 8% and the same shall be taken at 5% as declared by the assessee. In absence of any response by the assessee, Ld. CIT(A) had rightly decided the issue after thoroughly deliberating upon the merits of the issue. In view of such facts and circumstances, the order Ld. CIT(A) deserves to be sustained. 16.5 We have considered the sub ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s the submission by Ld. AR that the aforesaid amount pertains to assessment year 2012-13, and the appeal against the said addition was pending, therefore, the addition made cannot sustain in the eyes of law, the same is liable to be deleted. 8.18 On the other hand, Ld. CIT-DR submitted that the addition was made by the Ld. AO in the impugned assessment order u/s 153A, just to keep the issue alive in the matter and have made a noting in the assessment order itself that the impugned addition / disallowance was made during the scrutiny assessment u/s 144 r.w.s. 147 of the Act, by the Ld. AO Ward-2(1), Raipur. While sustaining the said addition inadvertently Ld. AO had added the amount in AY 2011-12 instead of AY 2012-13 originally wherein the said addition was made. It was the submission that the mistake occasioned was just a Bonafide error on the part of Ld. AO, which could have been corrected by the Ld. CIT(A), during the appellate proceedings before him, who has the powers coterminous with that of Ld. AO, however, such facts could not surfaced before the First Appellate Authority in absence of assessee's non cooperation and absence on all the occasions when the matter was fixed fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hare premium received by the assessee company by wrongly treating the same as unexplained cash credit u/s 68 of the Act. (b) For that the Ld. CIT(A) failed to appreciate that no addition u/s 68 could be made in regard to the share capital / premium raised in the assessment framed u/s 153A inasmuch as no incriminating material was found in the course of search in connection therewith. 4. For that on the facts and in the circumstances of the case, the Ld. CIT (A) ought to have directed the A.O. to apply a reasonable G.P rate as against the G.P rate of 8% applied by the A.O. on undisclosed sales, thereby, wrongly confirming the addition of Rs. 8,46,449/- over and above the declared G.P. of Rs. 5,07,160/- in the return filed u/s 153A. 5. For that the Ld. CIT(A) ought to have directed the A.O. to compute proper interest u/s 234A, 234B and 234C as per law. 6. The appellant craves leave to add further grounds of appeal or alter the grounds at the time of hearing. 9.1 The additional grounds of appeal raised by the assessee vide application dated 12.12.2024: 1. For that the A.O. was not justified in passing a consolidated / common order for A.Y: 2011-2012 to 2019-2020 in vio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... amed u/s 153A inasmuch as no incriminating material was found in the course of search in connection therewith. 4. For that on the facts and in the circumstances of the case, the Ld. CIT(A) ought to have applied a reasonable G.P rate as against the G.P rate of 8% applied by the A.O. on undisclosed sales, thereby, wrongly confirming the addition of Rs. 3.06.75,207/- over and above declared G.P. of Rs. 3,32,68,687/- in the return med u/s 153A. 5. For that, on the facts and in the circumstances of the case, the Ld. CIT (A) grossly erred in confirming the disallowance of Rs. 6,94,878/- made by the A.O. on account of alleged commission @ 1% of the alleged undisclosed sale. 6. For that the Ld. CIT(A) ought to have directed the A.O. to compute proper interest u/s 234A, 234B and 234C as per law. 7. The appellant craves leave to add further grounds of appeal or alter the grounds at the time of hearing. 10.1 The additional grounds of appeal raised by the assessee vide application dated 12.12.2024: 1. For that the A.O. was not justified in passing a consolidated / common order for A.Y: 2011-2012 to 2019-2020 in violation of the mandate of sec. 153D of the Act, thereby, vitiatin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... culled out from the order of Ld. CIT(A), which reads as under: 6. Ground No. 2 :- During the search & seizure the data backup of Laptop it is found that M/s Sarthak Ispat Pvt. Ltd has provided sales bills during the F.Y. 2012-13 and 2013-14 and after receiving funds through RTGS returned cash after deduction VAT to the various parties. Part of such sales bills have been confronted to Shri Vijay Garg and Shri Chaitanya Garg during the search proceedings wherein they have admitted that these bills had not been accounted for. The statement of Vijay Garg and Chaitanya Garg has already been part of original appraisal report. The details of sales bill are as under :- Name of the party Period Qty. RTGS Received Cash paid Reghuveer 01.09.2012 to 19.09.2012 194.820 58,61,039 59,49,880 Rooplaxmi 01.10.2012 to 04.10.2012 197.615 59,50,973 56,97,084 Rooplaxmi 05.10.2012 to 08.10.2012 236.090 71,26,327 68,22,400 Rooplaxmi 08.10.2012 to 10.10.2012 118.570 35,81,093 34,28,413 Raghuveer 29.11.2012 103.110 31,06,895 29,39,447 Hi-Tech 05.10.2012 to 19.10.2012 131.320 44,96,543 36,20,000 Mahamaya Rolling Mills 05.10.2012 to 07.10.2012 100.63 34,43,086 33,70, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an appeal before the Ld. CIT(A), however, assessee remained absent before the Ld. CIT(A) on various occasions, when the matter was fixed for hearing. Ld. CIT(A). Thereafter, Ld. CIT(A) had deliberated on the issue in absence of any representation on behalf of the assessee based on material available on records. The observation of the Ld. CIT(A) after deliberating upon the merits on the issue are that "I find that Ld. AO is justified in assessing the total income of the appellant as discussed above, when repeated opportunity in this regard was provided clearly shows that the appellant is not interested in pursuing the appeal. In this circumstance, I have no option but to confirm the addition made by the Ld. AO and dismissed the grounds of appeal of appellant." 17.3 Aggrieved with the aforesaid decision with the Ld. CIT(A), assessee preferred an appeal before this tribunal, which is under consideration before us. 17.4 Ld. CIT-DR, on the issue of addition by the Ld. AO on account of commissioner @1% on bogus sales transacted by the assessee during the year under consideration, had submitted that the assessee remains non-responsive before the First Appellate Authority as also be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d. CIT(A) in confirming the addition made by the Ld. AO in absence of any plausible explanation by the assessee to dislodge the same. Further, we observe that the assessee's involvement in providing of Bogus Sales bills in lieu of commission was never disputed by the assessee, therefore, receipt of commission by the assessee on such bogus transactions cannot be doubted, therefore, the finding of Ld. AO that the assessee has received a commission from such transactions found to be of material substance. We, thus, in terms of such observations do not find any perversity in the decision of Ld. CIT(A), so we uphold the same. In result, Ground no. 4 of the assessee, therefore, stands dismissed.
10.4 In view of aforesaid observations / decision, IT(SS)A No. 13/RPR/2024 for the AY 2013-14, which is squarely covered by our decisions in assessee's own case as per details in the aforesaid tables, consequently, the appeal of assessee in IT(SS)A No. 13/RPR/2024, partly allowed.
11. In combined result, ITA No: 519 & 452/RPR/2024 and IT(SS)A No. 12 & 13/RPR/2024 are partly allowed, in terms of our aforesaid observations.
Order pronounced in the open court on 28/02/2025. X X X X Extracts X X X X X X X X Extracts X X X X
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