2025 (11) TMI 717

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....in these two appeals, they were heard together and are disposed of by this common order for the sake of convenience and brevity, though the quantum may differ. For the sake of our convenience, we are adjudicating on the facts of ITA No. 2166/DEL/2025 on the agreement that the underlying facts in ITA No. 2167/DEL/2025 are mutatis mutandis same. ITA No. 2166/DEL/2025 3. The grounds raised by the assessee read as under: 1. That the order of learned Commissioner of Income Tax (Appeals) is bad in law as well as on the facts and in the circumstances of the case. 2. That the learned Commissioner of Income Tax (Appeals) has erred in dismissing the contention of the appellant that proper opportunity of being heard was not pro....

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....f Income Tax (Appeals), has erred in upholding the invocation of the provisions of section 115BBE of the Act." 4. Brief facts of the case are that original return in this case was filed on 29.07.2022 declaring income of Rs. 1,57,76,550/-. A search and seizure operation u/s 132 of the Income-tax Act, 1961 [the Act, for short] was conducted on 17.11.2021 and on subsequent dates on different business and residential premises of Pacific Group of Cases. The case of the assessee was also covered during the course of search & seizure operation in this case. In the course of search proceedings at Locker No. 1132, Alaknanda Vaults Pvt. Ltd, East of Kailash, jewellery amounting to Rs. 1,72,07,965/- and bullion amounting to Rs. 34,52,843/- was foun....