2025 (10) TMI 293

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....017-18. Through the aforesaid appeal the Revenue has challenged order u/s 250 dated 22.09.2023 passed by the CIT(A), Chennai. Both the appeals are contesting identical issues and hence are adjudicated by way this common order. 2.0 Brief factual matrix of the case, narrated by the Ld. AO made addition of Rs. 4,25,00,000/- and Rs. 2,95,00,000/- in assessee's hands for AY-2016-17 and 2017-18 respectively. As per facts recorded by the Ld. AO search u/s 132 was conducted in the group cases of M/s. S.R.S. Mining, J.Sekar Reddy, K.Rathinam and S.Ramachandran on 08.12.2016. During the search incriminating documents were found from the premise of M/s. S.R.S. Mining vide annexure-ANN / MPK / NS / B&D / S-19 & S-20 and ANN / KGAR / MPKSSR / B&D / S....

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....make the impugned additions on the strength of seized documents and mere statement of Shri Sreenivasulu. 3.0 We have heard rival submissions in the light of material available on records. The Ld. Counsel for the assessee submitted that the Ld.CIT(A) has extensively covered and analyzed varied facets of this case and after correctly understanding and appreciating the same, he has concluded that no case of any addition is made out in assessee's case. Consequently he directed the Ld.AO to delete the addition. The Ld. Counsel for the assessee also submitted that while according relief the Ld. First Appellate Authority has appreciated the correct statutory provisions as well as judicial pronouncements surrounding the controversy. The Ld. DR w....