ORDER

PER BENCH:

These groups of 8 appeals are filed by the Revenue against the common order dated 10.01.2024 of the Commissioner of Income-Tax (Appeals)-11, Ahmedabad, (in short ‘the CIT(A)’), in respect of penalty orders passed under Section 271AA of the Income Tax Act, 1961 (in short ‘the Act’) relating to Assessment Years 2012-13 to 2019-20.

2. Since, the facts of all the cases are identical and common issue is involved, all the 8 appeals were heard together and are being disposed of vide this common order for the sake of convenience.

3. We will take ITA No.633/Ahd/2024 for A.Y. 2012-13 as the lead case.

4. The brief facts of the case are that a search operation u/s.132 of the Act was conducted on Priya Blue group on 19.11.2019 in the course of which the premise of the assessee company M/s. Best Oasis Ltd. was also covered. Thereafter, proceeding u/s. 153A of the Act was initiated in the case of the assessee for A.Ys. 2012-13 to 2019-20. The assessee had filed its return of income for A.Y. 2012-13 on 23.07.2021 declaring Nil income. The assessee is a non-resident company and wholly owned subsidiary of Priya Blue Industries Pvt. Ltd. (PBIPL). In the course of search at Mumbai Off