2025 (7) TMI 1360

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.... Adv. And Ms. Ishika Dua, CA For The Department : Ms. Suman Malik, CIT(DR) ORDER PER SATBEER SINGH GODARA, JM The instant batch of five appeals pertain to a single assessee herein, namely, M/s. Ess Aar Corporate Services Pvt. Ltd. All other relevant details thereof read as under: Sl. No. Appeal No. Appellant Respondent Order Appealed against 1. 2901/Del/2024 for AY....

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..../2024 for AY: 2011-12 Ess Aar Corporate Services Pvt. Ltd. ACIT, Central Circle, Karnal CIT(A)-3, Gurgaon's order dated 27.05.2024 passed in case no. 10357/CIT(A)- 3/GGN/2019-20, involving proceedings under section 143(3) r.w.s. 153A(1)(b) of the Act. 5. 2905/Del/2024 for AY: 2012-13 Ess Aar Corporate Services Pvt. Ltd. ACIT, Central Circle, Karnal CIT(A)-3, Gurgaon&#39....

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....backdrop that the department could hardly dispute the clinching fact that the learned lower authorities have nowhere made it clear in their respective findings that the assessee's alleged unexplained investments etc. made in its hands, are based on any seized material only. We thus quote PCIT Vs. Abhisar Buildwell Pvt. Ltd. (2023) 454 ITR 212 (SC) to conclude that the impugned assessments are not ....