JUDGMENT

M.R. SHAH, J.

As common question of law and facts arise in this group of appeals, and are with respect to common assessee, but with respect to different assessment years, all these appeals are being decided together by this common Judgment and Order.

2. For the sake of convenience, the facts of Civil Appeals arising from Special Leave Petition (C) Nos. 8449-8450/2017 arising from I.T.A. No. 453/2016 & Review Petition No. 16/2017 for Assessment Year 2008-09 are stated and considered. The facts in nutshell are as under:

2.1 By virtue of the authorization of the Director of Income Tax (Investigation), Chandigarh, a search and seizure operation under Section 132(1) of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’) was carried out on 8/9.04.2010 at the residential/business premises of Shri Tejwant Singh and Shri Ved Prakash Bharti group of companies at Karnal, Panipat and Delhi. A survey under Section 133A of the Act was also carried out at the business premises of M/s Super Mall (P) Limited – the assessee, at Karnal and New Delhi. That during the course of the