2025 (7) TMI 1773

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.... involving proceedings under section 153A r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), respectively. Heard both the parties. Case file perused. 2. Learned counsel's first and foremost substantive argument raised during the course of hearing is that both the lower authorities have erred in law and on facts in assessing the assessee under section 153A r.w.s. 143(3) of the Act despite the fact that no incriminating material had been found against him during the course of search in question on 09.06.2016 in Mr. Sunil Jain Group of cases. Her second substantive contention is that the learned lower authorities have further erred in law and on facts in assessing the entire gross receipts of one "Sh. Sunil Kum....

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....ing sums in these three assessment years. 5. Learned CIT(DR), on the other hand, has invited our attention to the Assessing Officer's identical detailed discussion that the latter has made it clear-cut case of a double PAN wherein the assessee Sh. Sunil Jain is none else but Sh. Sunil Kumar himself as per the overwhelming detailed evidence found against him right from page 7 onwards containing the detailed Investigation Wing's report against him. 6. Mr. Mahesh Kumar, learned CIT(DR), further takes us to para 2.10 onwards in assessment order inter alia proving that in the concerned company; both Sunil Kumar and Sunil Jain are found having the very email ID and availing the same auditors' services bank records as well as the DGFT, New Delhi....