2025 (9) TMI 1576

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....1961 ('the Act' in short), for the Assessment Years 2019-20 to 2022-23. 2. Since common facts and identical issues are involved in all these appeals, they were heard together and are being disposed of by this consolidated order for the sake of convenience and brevity. 3. In all these appeals, the grounds raised by the assessee are identical and reproduced hereunder for reference:- "1. In the law and facts and circumstances of the case, the Ld. CIT(A) ought to have quashed the assessment order being void-ab-initio, illegal and without jurisdiction and not following the natural justice. 2. In the law and facts and circumstances of the case, the Ld. CIT(A) has erred in holding that the appellant had received brokerage o....

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....the assessee and Shri Pravin Bavadiya were partners in the City Estate Group, sharing profits in the ratio of 20:80. The Assessing Officer alleged that unaccounted brokerage income of Rs. 84,00,000/- had been earned during the relevant period, based on certain seized documents. Accordingly Rs. 20,30,000/- was taxed in the hands of the assessee as his 20% share in the alleged brokerage. 5. We have heard the rival contentions and perused the material available on record. We find that the addition made in the hands of the assessee is based solely on alleged rough jottings or loose papers seized during the course of search, which purportedly relate to brokerage income. However, we find that, on identical facts and issue, the Coordinate Bench....

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.... assessee and not section 69A of the Act. Coming to the merits of the case, the learned A.R. has pointed out during the course of hearing invited our attention to the facts as reproduced by the learned CIT(A) in para 27 onwards on page 74 of the appellate order. It is noted that the addition was made based on a loose paper found from the premises of Mr. Divyang Vyas which has been reproduced at para 27.1 of the order of the CIT(A). It is noted that the addition of Rs. 43.50 lacs has been made on the basis of instances mentioned at page No.55 of the seized material, Annexure A-3, sr. No. 1 to 9. The items which have been mentioned in the above list do not indicate the name of the property, the details of purchaser - seller and, therefore the....