ORDER

PER: RATHOD KAMLESH JAYANTBHAI, AM Because the revenue was dissatisfied with the finding given in the order of the Learned Commissioner of Income Tax (Appeals)-4, Jaipur [ for short CIT(A) ] dated 11.12.2024 & 12.12.2024 for the assessment years 2013-14 to 2015-16 these appeals were filed. That order of the ld. CIT(A) arises because the assessee has challenged orders dated 19.03.2020, 19.03.2021 & 06.01.2022 passed under section 201(1)/201(1A) of the Income Tax Act 1961 [ for short “Act”) by the ITO(TDS), Alwar [ for short AO].

2.1 In ITA No. 79/JPR/2025 the Revenue has raised the following grounds of appeal:-

“1. Whether on the facts and in circumstances of the case in law, the ld. CIT(A) has erred in deleting the addition of Rs. 59,11,080/- made u/s 201(1) along with interest u/s 201(1A) of Rs. 42,55,977/- in respect of payments of Rs. 5,91,10,794/- made to three concerns namely M/s Saraya Distilleries Ltd., Pay Fair Enterprise and United Spirits Ltd. under the head “Franchise Expenses” holding that the impugned payments made by the assessee company does not come in the ambit of section 194J of the Income Tax Act, 1961 .”

2.2 In ITA No. 80/JPR/2025 the Revenue has raised t