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2025 Supreme(Online)(ITAT) 4010

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
DR. B.R.R. KUMAR, VP, Ms. SUCHITRA KAMBLE, J
Ashish Prafulbhai Patel – Appellant
Versus
DCIT, Central Circle-1(3), Ahmedabad – Respondent


Advocates:
For the Appellants/Petitioners: Shri Vartik Chokshi, Shri Biren Shah
For the Respondents: Shri Alpesh Parmar

आदेश/O R D E R

PER DR.B.R.R. KUMAR, VICE-PRESIDENT:

The above-captioned appeals have been filed by both the Revenue and the Assessee against the orders of the Ld. Commissioner of Income Tax (Appeals), Ahmedabad [hereinafter referred to as "CIT(A)"], passed under Section 250 of the Income Tax Act, 1961 [hereinafter referred to as "the Act"], for the Assessment Years (AYs) 2004–05 and 2006–07. In addition, the Assessee has filed cross-objections for both of the aforementioned assessment years. For AY 2003–04, an appeal has been filed by the Revenue, and a corresponding cross-objection has been filed by the Assessee. Since the issues involved in the cross appeals filed by both parties and objection raised by assessee in the C.Os. are arising from the search action carried out by the Department on 04.08.2006, all these Appeals are taken together and decided through common order.

2. The brief facts of the case are that the assessee is engaged in the business of real estate dealings and financing activities. The assessee belongs to Radhe Group, Ahmedabad. During the A.Y. under consideration, assessee was running three proprietary concerns in his name which were (i) Abhyudaya Finance, (ii)

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