2025 (6) TMI 788

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....014-15 respectively arising from the respective assessment orders passed by the AO tabulated hereunder:- Sr. Nos. ITA Nos. CIT(A) Order dated Assessment Order dated Assessment Order passed under section 1. 1298/Del/2023 [AY 2008-09] CIT(A)-3, Gurgaon order dated 27.02.2023 30.03.2016 153A(1)(b) r.w.s. 143(3) of the Income Tax Act, 1961 2. 1299/Del/2023 [AY 2009-10] -Do- -Do- -Do- 3. 1300/Del/2023 [AY 2010-11] -Do- -Do- -Do- 4. 1301/Del/2023 [AY 2011-12] -Do- -Do- -Do- 5. 1302/Del/2023 [AY 2012-13] -Do- -Do- -Do- 6. 1303/Del/2023 [AY 2013-14] -Do- -Do- -Do- 7. 1304/Del/2023 [AY 2014-15] -Do- -Do- 143(3) of the Income Tax Ac....

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....e and therefore, there is nothing incriminating in it. [ii] Besides, the so-called incriminating documents found at the premises of the other person, can at best give rise to proceedings under s. 153C or 147 of the Act. The assessment carried out under s. 153A based on incriminating material found in the premises of the other concerns does not give rise to jurisdiction under s. 153A of the Act; [iii] having rejected the books of accounts as well as purchase and sales declared by the assessee, the AO has adopted the gross profits margin declared by the assessee based on such allegedly non-genuine purchase/sales declared in the books. As self-evident, the book results have been accepted upto the stage of determination of gro....

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....warrant to entertain a different view in the present appeal. Based on other decisions of Co-ordinate Benches, the protracted litigation must come to an end and relief needs to be given from such wrongful additions inconsonance with other judgements. 6. The Ld.CIT DR for the Revenue, on the other hand, relied upon the first appellate order and submitted that the documents showing salary payments and audit fee payments managed by the SSOL glaringly show that these concerns are paper concerns and therefore, the assessee is not eligible for any deduction of expenses and the additions made applying the gross profits margin should not be disturbed. 7. We have carefully considered the rival submissions. The controversy raised as narrated in ....