2025 (9) TMI 1757

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....dhu, CIT-DR ORDER Per Satbeer Singh Godara, Judicial Member: These assessee's twin appeals in ITA Nos. 6068 & 6109/Del/2025 for Assessment Years 2017-18 & 2018-19, arise against the CIT(A)-25, New Delhi's DIN & order No. ITBA/APL/M/250/2024-25/1069978542(1) & 1069978542(1) dated 28.10 .2024, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short " the Act"), respectively. 2. C....

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....had around 100 companies including the assessee which provided accommodation entries. He could hardly dispute that no such specific incriminating material found/seized during the course of search herein has been quoted by both the learned lower authorities so as to add the impugned alleged accommodation entries @ 4% as per PCIT vs. Abhisar Buildwell Pvt . Ltd. (2023) 454 ITR 212 (SC). 5. Learne....