TaxTMI 
TaxTMI 
2026 (6) TMI 1084
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.... Assessing Officer, DCIT/ACIT, Central Circle 28, Delhi (hereinafter referred as "the AO") u/s 153C of Income Tax Act, 1961 (hereinafter referred to as "the Act") for the A.Ys. 2014-15 & 2015-16, respectively. 2. Since the above captioned appeals were heard together and facts in issues are identical, both the appeals are being disposed of by this common order for the sake of convenience and brevity 3. Grounds of appeal filed by the assessee in ITA No.1332/Del/2026 are as under : 1. "That on the facts and circumstances of the case and in law, the order dated 23.01.2026 passed by the L.d. Commissioner of Income Tax (Appeals) [CIT(A)] under section 250 of the Income Tax Act, 1961 ("the Act") is illegal, bad in law and unsustaina....
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.... seized material have any bearing on the determination of the total income of the assessee as mandated by section 153C. 3.5. That the impugned assessment year falls beyond the block period of six years preceding the search year, which admittedly, in the present case, is Assessment Year 2022-23. 3.6. That even if the impugned assessment year is considered as a "relevant year" beyond the block period of six years, it could not have been reopened, as the Ld. AO failed to record any specific satisfaction regarding the fulfilment of the conditions prescribed under the fourth proviso to section 153A r.w.s.153C of the Act. 4. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in susta....
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.... AO u/s 69 or 69A on account of alleged unexplained investment, without bringing any material on record and merely on the basis of conjectures and surmises. 9. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in sustaining the addition of Rs.1,50,000/- made by the Ld. AO u/s 69C as unexplained expenditure on account of alleged commission paid on the transaction of Rs. 50,00,000/-. 10. That on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in sustaining the addition of Rs. 1,60,00,000/- made by the Ld. AO u/s 69A on account of alleged bogus transactions with M/s. Newwave Commercial Pvt. Ltd. and M/s. Euro Global Reinsurance, which are alleged to be bogus entit....
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....(Appeals) [hereinafter referred to as "CIT(A)"], both dated 23.01.2026 whereby it affirmed the orders of Ld. Assessing Officer (hereinafter referred to as "Ld. AO"), both dated 31.03.2023 passed u/s 153C of the Income Tax Act, 1961. DATE PARTICULARS REMARKS 18.10.2019 Search u/s 132 carried out on Alankit Group, Sh. Alok K Agarwal, Sh. Ankit Agarwal 16.03.2022 Satisfaction note was recorded by the AO of 'searched person' for AY 2010-11 to AY 2020-21 P. NO. 18-19 of PB 05.04.2022 Satisfaction note was recorded by the AO of other person/assessee' P.NO. 26 of PB 5. At the outset, learned Counsel for the assessee submitted that in the satisfaction note of the AO of the non-searched perso....
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....ATA24). 3. The transactions entered into by various beneficiaries with various shell entities controlled by Alok K Agarwal, against unaccounted cash or otherwise to take accommodation entries, are as tabulated below: Name of beneficiary F.Y. Transaction done with Amount debited to beneficiary Amount credited to beneficiary Sale Cubical In Tanuj Sharma 2014-15 SUNIL BHALA 64,15,500 Tanuj Sharma 2012-13 Cash 2,50,00,000 DCPL 25,00,000 25,00,000 EURO GLOBAL REINSURANCE 50,00,000 2013-14 EURO GLOBAL REISURANCE 50,00,000 NCPL 11,00,000 11,00,000 Cash 50,00,000 Tanuj Sharma and Anuj Sharma 2012-13 Cash ....