TaxTMI 
TaxTMI 
2026 (8) TMI 962
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....e in the case of the same assessee, arising out of the order dated 03.05.2024 passed by the Ld. Commissioner of Income Tax (Appeals)-11, Ahmedabad [hereinafter referred to as "the Ld. CIT(A)"] under section 250 of the Income-tax Act, 1961 (hereinafter referred to as "the Act") for Assessment Years 2017-18, 2018-19 and 2021-22, respectively. The present bunch also includes ITA No. 1347/Ahd/2024 filed by the Revenue in the case of Ratnatris Pharmaceuticals Pvt. Ltd., arising out of the order dated 29.05.2024 passed by the Ld. CIT(A) u/s. 250 of the Act for AY 2021-22. 2. Since the issues involved in these appeals are common and interconnected, and arise out of substantially identical facts, these appeals were heard together and are being d....
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....dition. 5. The learned CIT(A) has erred in not holding that the assessment order passed by AO is in gross violation of principles of natural justice. 6. The Appellant states that the search proceedings carried out in his case are beyond jurisdiction, illegal and void. The consequential assessment order passed is bad-in-law, illegal and void-ab-initio." 5. The assessee has raised following grounds of appeal in ITA No. 1270/Ahd/2024 for AY 2018-19:- "1. The learned CIT(A) has erred in not holding that the notice issued u/s. 148 of the Act is bad in law, illegal and void-ab-initio. The learned CIT (A) has further erred in not holding that procedure as per law was not followed while issuing the notice u/s. 148 of t....
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....facts and on the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 9,70,85,801 on account of unexplained & unaccounted expenses as per provision of Section 69C of the Act. 3. In the facts and on the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 67,574/- on account of accrued interest from other source u/s. 56 of the Act." 7. The Revenue, in the case of Ratnatris Pharmaceuticals Pvt. Ltd., has raised following grounds of appeal in ITA No. 1347/Ahd/2024 for AY 2021-22:- "1) In the facts and on the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 7,03,79,917/- (protective basis) u/s. 6....
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....hat the additions were based solely on third-party documents without any independent corroborative evidence. The Assessing Officer, however, rejected the explanation and made an addition of Rs. 1,83,92,648/- u/s. 69C of the Act on account of unexplained expenditure, besides assessing accrued interest of Rs. 48,302/- u/s. 56 of the Act. The reassessment was accordingly completed u/s. 147 read with section 143(3) of the Act, assessing the total income of the assessee at Rs. 2,08,17,340/-. 8.2 Aggrieved by the reassessment order, the assessee preferred an appeal before the Ld. CIT(A), who partly allowed the appeal. The assessee, being aggrieved by the findings of the Ld. CIT(A) sustaining the additions, is in further appeal before the Tribu....
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....pendent evidence to establish that the entries represented actual transactions undertaken by the assessee. It was further submitted that except for the handwritten notings in the seized diaries, no corroborative material whatsoever had been brought on record by the Assessing Officer to justify the addition u/s. 69C of the Act. 10.2 The Ld. DR, on the other hand, relied upon the assessment order and supported the findings recorded therein. It was submitted that the seized diaries, read together with the statement recorded under section 132(4) of the Act, constituted sufficient evidence to establish the unaccounted expenditure incurred by the assessee. 11. We have heard the rival submissions and perused the material available on record.....
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....202,802,508 2018-19 113,848,655 32,541,873 29,733,166 9,358,550 185,482,244 2019-20 120,743,303 51,680,239 3,914,800 16,077,515 192,415,857 2020-21 181,208,711 59,382,971 29,013,801 20,920,859 290,526,342 2021-22 123,699,898 65,575,117 31,662,994 34,628,745 255,566,754 Total 1,103,417,150 410,931,405 213,424,576 163,080,936 7,635,340 1,898,489,407 11.1 Since the amounts involved in the present case stands intrapolated in the hands of Shri Prakash Babulal Sanghvi and also confirmed by the Tribunal, no separate addition in this case is called for. For the AY 2021-22, from page Nos. 44 to 47 of the Ld. CIT(A)'....