JUDGMENT

Navin Chawla, J. (Oral)

The appeal has been heard by way of video conferencing.

CM 45430/2021 (exemption)

Allowed, subject to all just exceptions.

ITA 176/2021

1. The present appeal has been filed challenging the order dated 08.02.2021 passed by the learned Income Tax Appellate Tribunal, New Delhi, Delhi Bench 'C' (hereinafter referred to as the 'ITAT') in ITA No. 3982/DEL/2015 dismissing the appeal of the Revenue against the order dated 25.032015 passed by the Commissioner of Income Tax (Appeals) [hereinafter referred to as the 'CIT(A)'].

2. It is the case of the appellant that a search and seizure operation under Section 132 of the Income Tax Act, 1961 (in short, the 'Act') was carried out in the case of the respondent-assessee along with other companies which were controlled by the respondent's Directors on 12.12.2006. On the basis of the said search and seizure operation conducted, the respondent-assessee's case was selected for scrutiny and a notice under Section 143(2) of the Act was issued for AY 2009- 10.

3. Vide assessment order dated 29.12.2011, the Assessing Officer made additions of Rs. 3,35,87,118/- (Rupees three crore thirty-five lakh eighty seven thous