2025 (2) TMI 1619

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.... have been raised by the Revenue in both these appeals and the facts germane to the issues in appeal are identical, these appeals are taken up together for adjudication and decided by this common order. 3. Shri S.K. Chaterjee, representing the Department narrating facts of the case submitted that a search and seizure operation was carried out at the business premises of Golden Manor Group on 22.07.2015. The assessee is a partnership firm and is engaged in Real Estate Business. During the course of search and seizure operation one of the partners Shri A N Ahuja in his statement recorded u/s. 132(4) of the Income Tax Act, Income Tax Act, 1961(hereinafter referred to as 'the Act') made a disclosure of Rs. 5 crores for AY 2015-16 and Rs. 9 c....

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....e assessee is following Percentage Completion Method as per AS-7. In assessment proceedings, the AO could not point any defect in the working of the assessee or books of the assessee which were duly audited as per provision of section 44AB of the Act. In so far as, surrender of Rs. 5 crores/Rs. 9 crores in impugned assessment years, by Shri A N Ahuja Managing Partner, the statement was retracted next day. The AO has not made any addition on the basis of surrender of income. The ld. Counsel for the assessee submitted that the AO instead of taking actual cost and actual revenue has adopted projected figures which were filed before the bank. The AO conveniently ignored actual figures which were submitted during the course of assessment proceed....