TaxTMI 
TaxTMI 
2026 (8) TMI 669
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....18/Del/2026, ITA No. 6981/Del/2025, ITA No. 6150/Del/2025 SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER For the Assessee : Dr. Manas Shankar Ray, Adv., Ms. Neelu Mohan, Adv., Shri Shashwat Saxena, Adv. For the Department : Shri Raghunath, CIT(DR) ORDER PER BENCH: The instant batch of 39 cases involves the three assessees herein i.e., M/s Anmol Tradex Pvt. Ltd, M/s Bal Gopal Importers and Exporters Pvt. Ltd. & M/s Pratyaksh Apparels Pvt. Ltd. All other remaining details thereof stand tabulated (taxpayer-wise) as under: Sl. No. Appeal No. Appellant Respondent (Cross-Objector) Order Appealed against 1-2 ITA No. 5378/Del/ 2025 along with C.O. No. 205/Del/2 026 Assessment Year: 2011-12 ACIT, Central Circle-25, New Delhi Anmol Tradex Pvt Ltd. F-3, 1st Floor, TDI Fun Republic Mall, Moti Nagar, New Delhi- 110 015 CIT(A), Delhi's-31's order dated 27.05.2025 having DIN & Order No. ITBA/APL/3/250/2025- 26/1076488841(1) involving proceedings under Section 153C r.w.s. 143(3) of the Act. 3-4 ITA No. 5379/Del/ 2025 along with C.O. No. 206/Del/2 026 Assessment Year: 2012-13 ACIT, Central Circle-....
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....CIT, Central Circle-25, New Delhi Anmol Tradex Pvt Ltd. F-3, 1st Floor, TDI Fun Republic Mall, Moti Nagar, New Delhi- 110 015 CIT(A), Delhi's-31's order dated 27.05.2025 having DIN & Order No. ITBA/APL/3/250/2025-26/ 1078239982(1) involving proceedings under Section 153C r.w.s. 143(3) of the Act. 16 ITA No. 6927/Del/202 5 ; Assessment Year: 2018-19 ACIT, Central Circle-25, New Delhi Anmol Tradex Pvt Ltd. F-3, 1st Floor, TDI Fun Republic Mall, Moti Nagar, New Delhi- 110 015 CIT(A), Delhi's-31's order dated 27.05.2025 having DIN & Order No. ITBA/APL/3/250/2025- 26/1078230982(1) involving proceedings under Section 153C r.w.s. 143(3) of the Act. 17 ITA No. 8051 /Del/2025; Assessment Years: 2013-14 ACIT, Central Circle-25, New Delhi Pratyaksh Apparels Private Limited H-84, 1st Floor, Shivaji Park, Delhi- 110026 CIT(A), Delhi's-31's order dated 05.08.2025 involving proceedings under Section 153C r.w.s. 260 of the Act. 18 ITA No. 8052/Del/202 5; Assessment Years: 2014-15 ACIT, Central Circle-25, New Delhi Pratyaksh Apparels Private Limited H-84, 1st Floor, Shivaji Park, Delhi- 110026 CIT(A), Delhi's-31's or....
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.... ACIT, Central Circle-25, New Delhi Bal Gopal Importers & Exporters Private Limited WZ-106/141, Rajouri Garden Extension, New Delhi- 110 027 CIT(A), Delhi's-31's order dated 27.05.2025 involving proceedings under Section 153C r.w.s. 143(3) of the Act. 30-31 ITA No. 5388/Del/ 2025 along with C.O. No. 215/Del/2 026 Assessment Year: 2014-15 ACIT, Central Circle-25, New Delhi Bal Gopal Importers & Exporters Private Limited WZ-106/141, Rajouri Garden Extension, New Delhi- 110 027 CIT(A), Delhi's-31's order dated 27.05.2025 involving proceedings under Section 153C r.w.s. 143(3) of the Act. 32-33 ITA No. 5389/Del/ 2025 along with C.O. No. 216/Del/2 026 Assessment Year: 2015-16 ACIT, Central Circle-25, New Delhi Bal Gopal Importers & Exporters Private Limited WZ-106/141, Rajouri Garden Extension, New Delhi- 110 027 CIT(A), Delhi's-31's order dated 27.05.2025 involving proceedings under Section 153C r.w.s. 143(3) of the Act. 34-35 ITA No. 5390/Del/ 2025 along with C.O. No. 217/Del/2 026 Assessment Year: 2016-17 ACIT, Central Circle-25, New Delhi Bal Gopal Importers & Exporters Private Limited WZ-106/141, Rajouri Garden ....
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....4 ITR 212 (SC). Learned counsel takes us to the CIT(A) impugned identical/common lower appellate order (in the first assessee's case) to the very effect; reading as under: "52. Upon careful consideration of the entire gamut of facts and circumstances of the case and the case laws cited above, I am of the considered view that the AO is not justified in making the additions in the assessment orders passed u/s 153C r.w.s 153A of the Act for AYs 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 and 2017-18 as the same are not in accordance with the material found in a search on searched person and the material which has been basis of such additions has neither been noticed, examined nor considered in the satisfaction note recorded by him. Therefore, I find that the said additions are not sustainable in law and as such are liable to be deleted. I hold accordingly. Hence, all the additions made by the AO in the assessment orders so passed for AYs 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 and 2017-18 are hereby deleted. 53. In view of the foregoing discussion, in conclusion, the appeals for AYs 2011-12, 2012- 13, 2013-14, 2014-15, 2015-16, 2016-17 and 2....
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.... the assessees as well as the department have come in their respective appeals or cross-objections; as the case may be, before the tribunal. 4. Learned CIT(DR) vehemently submits that the Assessing Officer's various assessments framed in all these cases had duly discussed the relevant incriminating material. We find no merit in the Revenue's case herein in all these "unabated" assessment years since the learned CIT(A) has settled the issue that this is a clearcut instance of lack of any incriminating material forming the very basis for making the impugned additions in these three assessee's hands; whatsoever. 5. Learned counsel at this stage further seeks to buttress the point that the relevant assessments herein framed in all these three assessee's cases happen to be u/s 153C of the Act. He takes us to pages 313 to 318 in case of M/s Anmol Traders Pvt. Ltd. that the Assessing Officer of the searched person had recorded his former round of section 153C satisfaction on 19.02.2021 that the corresponding seized material in fact "belongs to" the assessee in assessment years 2013-14 to 2019-20. That being the case, the Revenue could hardly dispute that section 153C....
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....o. Assessee Appeal No. Assessment Year Result 1 C.O. No. 205/Del/2026 Assessment Year: 2011- 12 Allowed 2 C.O No.206/Del/2026 Assessment Year: 2012- 13 Allowed 3 C.O. No. 207/Del/2026 Assessment Year: 2013- 14 Allowed 4 C.O. No. 208/Del/2026 Assessment Year: 2014- 15 Allowed 5 C.O. No. 209/Del/2026 Assessment Year: 2015- 16 Allowed 6 C.O. No. 210/Del/2026 Assessment Year: 2016- 17 Allowed 7 C.O. No. 211/Del/2026 Assessment Year: 2017- 18 Allowed 8 ITA No. 6149/Del/2025 Assessment Year: 2015- 16 Allowed 9 C.O. No. 212/Del/2026 Assessment Year: 2011-12 Allowed 10 C.O. No. 213/Del/2026 Assessment Year: 2012-13 Allowed 11 C.O. No. 214/Del/2026 Assessment Year: 2013-14 Allowed 12 C.O. No. 215/Del/2026 Assessment Year: 2014-15 Allowed 13 C.O. No. 216/Del/2026 Assessment Year: 2015-16 Allowed 14 C.O. No. 217/Del/2026 Assessment Year: 2016-17 Allowed 15 C.O. No. 218/Del/2026 Assessment Year: 2017-18 Allowed 16 ITA No. 6150/Del/2025 Assessment Year: 2018-19 Allowed The department's appe....