2025 (3) TMI 1933

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....1.12.2022 passed u/s 153C r.w.s. 143(3) of the Income Tax Act, 1961 (hereinafter referred as 'the Act') by the ACIT, Central Circle- 16, New Delhi (hereinafter referred to as the Ld. AO). 2. Heard and perused the record. The factual background of this appeal of the Revenue is that a search u/s 132 of the Act was conducted in the case of Rakesh Jain Group on 02.11.2017. the case of Shri. Prahlad Kumar Aggarwal was also covered under search operation. On perusal of seized data/documents in the case of Rakesh Jain Group of cases certain documents were found pertaining to Shri Ajay. The AO of the searched persons has recorded his satisfaction dated 10.08.2021 and handed over the seized material to the AO of the other person, i.e., Shri Ajay ....

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....addition of Rs. 15,93,94,200/- the additions referred to by Ld. CIT(A) w.r.t investments made by AGC Projects Pvt. Ltd., DKM Developers Pvt. Ltd. and M/s Alethea Infracon Pvt. Ltd. amounting to Rs. 11,40,69,200/- (the addition of Rs. 11,14,69,200/- instead of Rs. 11,40,69,200/- mentioned in assessment order) Rs. 1,63,60,000/- and Rs. 3,15,65,000/- respectively pertains to A.Y 2014-15. Whereas, in the instant matter, the addition to the income of the assessee has been w.r.t transaction for A.Y. 2018-19. 5. It is, therefore, prayed that the order of the Ld. CIT(A) may be set aside and that of the AO may be restored to the above extent. 6. (a) The order of the Ld. CIT(A) is erroneous and not tenable in law and on facts. (b) T....

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....nt of investment written From in cheque as well as in cash before the name of Sh. Ajay Choudhary is same which is written in the name of the three companies i.e. AGC Projects Private Ltd., DKM Developers (P) Ltd and M/s Alethea Infracon Pvt. Ltd. Further, from the perusal of assessment order of these three companies, it has been also found that the cash investments totaling to Rs. 15,93,94,200/- have been substantially added in their hands as well. Further, M/s Alethea Infracon Pvt. Ltd. has also submitted that it has accepted the assessed income and has not filed further appeal against the assessment order. Therefore, the same amount of unaccounted investment has been added twice in the hands of appellant and the three companies. In the st....