ORDER

PER KUL BHARAT, JM :

Both appeals filed by the assessee are directed against the orders passed by Ld.CIT(A)-3, Gurugram dated 29.03.2023 and 27.03.2023 for the assessment years 2014-15 and 2015-16 respectively. Since the similar grounds have been raised, both appeals of the assessee were taken up together for hearing and are being decided by way of this consolidated order for the sake of brevity.

ITA No.1562/Del/2023 [Assessment Year : 2014-15]

2. First, we take up the appeal of the assessee in the Assessment Year 2014-15 with ITA No. 1562/Del/2023. The assessee has raised following grounds of appeal:-

1. “That having regard to the facts and circumstances of the case, Ld. CIT (A) has erred in law and on facts in confirming the action of Ld. A.O. in assuming jurisdiction u/s 153A and the consequent assessment proceedings in the case are bad in law and against the facts and circumstances of the case and void-ab-initio and basic jurisdictional conditions and pre-requisites under section 153A were not met.

2. That in any case and in any view of the matter, the assessment framed under section 153A of the Act, is bad in law and against the facts and circumstances of the case.

3. That