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2025 Supreme(Online)(ITAT) 2962

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Dr. BRR Kumar, VP, T.R. Senthil Kumar, J
M/s. K. Mehta & Co. – Appellant
Versus
Income Tax Department – Respondent


Advocates:
For the Appellants/Petitioners: Shri Tej Shah, AR
For the Respondents: Shri A.P. Singh, CIT-DR

Table of Content
1. cross-appeals regarding assessment orders and the common issue of land purchase. (Para 1 , 2)
2. assessment order details and objection from the assessee regarding third-party reliance. (Para 3 , 4 , 6)
3. court held reliance on unverified statements is insufficient. (Para 7 , 8)
4. final decision on the appeals based on the reasons provided. (Para 9)

आदेश/ORDER

PER T.R. SENTHIL KUMAR, JUDICIAL MEMBER:

These cross-appeals are filed by two different assessees and by Revenue as against separate appellate orders both dated 31/07/2024 passed by the Commissioner of Income Tax [Appeals]-11, Ahmedabad [hereinafter referred to as “the CIT(A)] arising out of the separate assessment orders passed u/s.153C of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) relating to the Assessment Year (AY) 2020-21.

2. Since the common issue of purchase of land by the above two assessees as co-owners in the ratio of 50% each and additions are made at 50% each on the above co-owners, therefore for the sake of convenience, the above appeals are disposed of by this consolidated order. IT(SS)A No.74/Ahd/2024 for AY 2020-21 in the case of M/s. K. Mehta & Co. is taken as the lead ca

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