ORDER

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:

These appeals are filed by the Department and Assessee against the order of Commissioner of Income Tax (Appeals)-12 (in short “CIT(A)”), Ahmedabad vide separate orders dated 26.07.2019, 05.12.2019, 27.08.2019 and 25.03.2021 passed for A.Ys. 2011-12, 2012-13, 2014-15 and 2017-18.

We shall first start the Department’s appeal for A.Y. 2011-12 in IT(SS)A No. 449/Ahd/2019:

2. The Department has raised the following grounds of appeal:

“1. On the facts and in the circumstances of the case and in law, the ld. CIT(A) has erred in holding that any addition during the assessment u/s.l53A has to be confined to the incriminating material found during the course of search u/s. 132(1) of the Act, even though, there is no such stipulation in sec. 153 A of the Act.

2. On the facts and in the circumstances of the case and in law, the ld. CIT(A) has erred in not appreciating that sec. 153A requires a notice to be issued requiring the assessee to furnish his return of income in respect of each assessment year falling within six assessment years and to assess or re-assess the total income of those six assessment years, and that the scheme of assessment or re-a