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2025 (11) TMI 995

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.... details of the orders of the lower authorities are as under :- ITA No. & Assessment Year CIT(A) [ld. FAA] who passed the order Appeal No. & Date of order of the CIT(A) AO who passed the assessment order & Date of order Section of the IT Act under which the AO passed the order 5233/Del/2024 2018-19 CIT(A)- 27, New Delhi CIT(A), Delhi - 27/10432/2017-18, Dated 09.10.2024 DCIT, Central Circle-20, New Delhi, dated 29.03.2023 147 r.W.S. 143(3) 5234/Del/2024 2019-20 - Do CIT(A), Delhi - 27/10861/2018-19, dated 09.10.2024 - Do - - Do - 5235/Del/2024 2020-21 - Do - CIT(A), Delhi - 27/10563/2019-20, dated 09.10.2024 - Do - - Do - 5245/Del/2024 2021-22 - Do - CIT(A), Delhi - 27/100....

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....s been made basis for making the additions. It was also submitted that in fact, no specific questions were put up with regard to this document and, even if some incriminating fact was mentioned, the same stood withdrawn by way of an affidavit of retraction. 4. This has been countered by the ld. DR by submitting that approvals granted under the Act are merely administrative in nature and after examining all the records, approvals are granted and there is a presumption of application of mind. It was submitted that even using the term 'mechanical approval' is a misnomer and unless prejudice is established, approval granted cannot be questioned more so, when objection is not raised at the time of assessment proceedings. On merits, it....

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....  2020-21 1.5-2 cr.   2021-22 2 cr.   6. The assessee company had explained the contents of the said piece of paper submitting that they were merely rough estimates/projects pertaining to venture, but, the said business could never start. The AO rejected the books of account to the extent of unaccounted sales and made addition u/s 28 of the Act by calculating the net profit margin of 15% on unaccounted sales. Therefore, the aforesaid amounts as calculated were added to the income of the assessee which were challenged by the assessee before the ld.CIT(A). However, the assessee failed giving rise to these appeals. As for convenience we shall refer to grounds of AY 2018-19 and paperbook for same year for our....

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....confirming the action of Ld. AO in making estimated addition of Rs. 18,75,000/-,is illegal, bad in law and against the facts and circumstances of the case and the same is not sustainable onon legal and factual grounds. 5. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in rejecting the books of accounts of the assessee company and that too without any basis and without appreciating the facts and circumstances of the case. 6. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other." 7. We have carefully gone....