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2024 Supreme(Online)(ITAT) 644

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
POLO COMPUTERS & SOFTWARES PRIVATE LIMITED DELHI – Appellant
Versus
ACIT CENTRAL CIRCLE-13 DELHI – Respondent


O R D E R

PER VIMAL KUMAR, JM:

1. These three appeals filed by assessee are against order dated 13.12.2022 (for A.Ys. 2013-14 & 2014-15) and dated 29.11.2022 (for A.Y. 2015-16) of Learned Commissioner of Income Tax (Appeals)-28, New Delhi [hereinafter referred to as ‘Ld. CIT(A)’] arising out of assessment order dated 28.12.2018 of the Assistant Commissioner of Income Tax, Central Circle-13, New Delhi (hereinafter referred as ‘Ld. AO’) under section 153C r.w.s 143(3) of the Income Tax Act, 1961 [hereinafter referred to as “the Act”].

2. All the three captioned appeals involve similar facts and issues. For facility of convenience, all three appeals were heard together and are being disposed of by a common order.

3. We shall first take up the A.Y. 2013-14 for adjudication purposes.

ITA No. 1358/Del/2023 for A.Y. 2013-14 :

4. Brief facts leading to this case are that a search and seizure operation under section 132 of the Act was conducted on 23.07.2015 and subsequent dates in different business and residential premises of “Shri Deepak Agarwal, Shri Mukesh Kumar and others” group of cases, based at Delhi, allegedly entry operators providing accommodation entries to beneficiaries. As per Ass

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