2025 (2) TMI 1774

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....ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: These assessee's twin appeals in ITA Nos. 269 & 270/Agr/2024 arise against the CIT(A)/NFAC, Delhi's DIN & order No. ITBA/NFAC/S/250/2024-25/1065273316(1) & ITBA/NFAC/S/250/2024-25/1065226188(1) order dated 29.05.2024 and 30.05.2024, for Assessment Years 2015-16 and 2017-18, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in shor....

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.... 251(1)(a) enhancement in the given facts involved herein. 5. We find no merit to accept the Revenue's foregoing vehement contentions. This is for the precise reason that once the Assessing Officer's identical assessment discussion had treated the assessee's cash deposits in both these assessment years as his business income liable to be assessed @8%, the learned CIT(A)'s enhancement could not ....