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2024 Supreme(Online)(ITAT) 3706

INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Shri Chandra Poojari, AM, Shri Keshav Dubey, JM
Smt. Sheetal Borkar – Appellant
Versus
Shri D.K. Mishra – Respondent


Advocates:
For the Appellants/Petitioners: Smt. Sheetal Borkar, A.R.
For the Respondents: Shri D.K. Mishra, D.R.

ORDER

PER BENCH:

These appeals by assessee are directed against common order of CIT(A) for the assessment years 2013-14 to 2018-19 dated 18.12.2023. Since these appeals are related to a single assessee emanated from the common order of CIT(A), these appeals are clubbed together, heard together, and disposed of by this common order for the sake of convenience. The grounds of appeal raised by the assessee as follows:

ITA 485 of 2024 (2013-14)

1. The learned CIT(A), erred in passing the order in the manner he did.

2. The learned CIT(A), is not justified in law in making additions u/s 69B amounting to Rs. 84,00,000/- purely on assumptions and presumptions based on the loose sheet found at the time of search.

3. The learned CIT(A), has overlooked the facts that, no additions/disallowances u/s 153A can be made for the assessment year under questions, without the corroborative evidence unearthed and the original assessment has not abated as on the date of search.

4. The learned CIT(A), has erred in not considering the decision, which are squarely applicable to the appellant's case, i) CIT vs. Lancy constructions (237 taxmann 728) (kar), ii) CIT (central) III vs. Kabul Chawla (234 taxmann 300) (

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