2025 (11) TMI 454

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.....08.2023; respectively passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the "Act") and relate to Assessment Years (A.Ys.) 2014-15 to 2017-18. 2. At the outset itself it was stated that the issue arising in all the appeals of the assessee was common, pertaining to the addition made on account of alleged accommodation entry taken by the assessee. Therefore, all the appeals were taken up together for hearing and are being disposed of vide this common consolidated order. 3. The quantum of accommodation entry alleged to have been taken by the assessee in each year is as under: Sl. No. ITA No. A.Y. ADDITION 1 ITA No.830/Ahd/2023 2014-15 Rs. 17,16,95,541/- 2 ITA No.831/Ahd/2023 ....

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....d. Counsel for the assessee pointed out that in succeeding years i.e. A.Y. 2019-20 & 2020-21, the case of the assessee in his individual capacity was reopened for the same reasons as in the years impugned before us, i.e on the basis of information that M/s. Kabra & Co. had taken accommodation entry from certain accommodation entry providers. He pointed out that during assessment proceedings in the said years, the assessee had again pointed out that M/s. Kabra & Co. was the proprietorship concern of the assessee's HUF and this fact was verified by the AO and no addition accordingly made in the said years i.e. A.Ys. 2019-20 & 2020-21, in the hands of the assessee. He pointed out that the assessment orders for these two years record the noting....

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....at this contention of the assessee is a matter of fact and needs to be established in each year. Considering the contention of both the sides, with the AO having verified concerned bank account to belong to the HUF of the assessee, and not the assessee in other years, and the DR contending this fact to be established in the impugned year, we consider it fit to direct the DR to seek a report from the AO regarding the impugned fact. The AO may conduct necessary inquiries in this regard and even ask to submit necessary details/information in the assessee this regard. The DR is directed to submit the AO's report on the next date of hearing fixed on 16/04/2025. Appeal to continue as part heard." 7. Thereafter, the matter....