2026 (8) TMI 1720

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....5); 1085385559(1) - (A.Y. 2015-16); 1085385629(1) - (A.Y. 2016-17); 1085385702(1) - (A.Y. 2017-18); 1085385745(1) - (A.Y. 2018- 19); 1085385802(1) - (A.Y. 2019-20); 1085385877(1) - (A.Y. 2020-21) involving proceedings under sections 143(3) r.w.s 153A of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'); respectively. 2. Heard both the parties at length. Case files perused. 3. It transpires during the course of hearing that all the instant fourteen cross appeals filed by the Revenue and the assessee emanate from the learned departmental authorities' search action dated 27.12.2019 carried out in M/s DAG group of companies etc. The same admittedly culminated in the impugned seven assessments framed in the assessee's case on....

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....f commission being 3.6% is added to the total income of the appellant. Accordingly, out of total loan disbursed amounting to Rs. 30,68,93,809/-, loan of Rs. 3,06,89,380/- is considered to be accommodation entries and commission of Rs. 11,04,817/- Is hereby added to the total income of the appellant (3,06,89,380/- 3.6%). Accordingly, these grounds of appeal are partly allowed." It is in this identical factual backdrop that both the Revenue as well as the assessee have filed their instant seven cross appeals each before the tribunal. 5. Learned counsel at this stage seeks to canvas the assessee's legal ground that all these seven assessments dated 29.09.2021 framed in its case are non-est in the eyes of law for want of valid section 153....