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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI M. BALAGANESH, ACJ, MS MADHUMITA ROY, J
M/S. GARDEN VIEW FOODS PVT. LTD. DELHI – Appellant
Versus
PR. CIT- 3 NEW DELHI – Respondent
ORDER
PER M. BALAGANESH, A. M.:
1. The appeals in ITA No. 3225 & 3226/Del/2017 for AYs 2011-12 and 2012-13, arises out of the order of the Commissioner of Income Tax (Appeals)-3, New Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 21.03.2017 against the order of assessment passed u/s 153A/143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 22.02.2013 by the Assessing Officer, DCIT, Central Circle-28, New Delhi (hereinafter referred to as ‘ld. AO’).
2. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience.
3. The only identical issue to be decided in both these appeals is validity of assumption of revision jurisdiction u/s 263 of the Act by the ld PCIT.
4. We have heard the rival submissions and perused the material available on record. A search and seizure action u/s 132 of the Act was carried out in Ocus Group of cases on 12.02.2013 including the assessee. The case of the assessee was centralized u/s 127 of the Act dated 26.04.2013 passed by the ld CIT-IV, Delhi. Notice u/s 153A of the Act was issued on 25.08.2014 requiring the assessee to file
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