ORDER

PER ABY T. VARKEY, JM:

These are appeals preferred by the assessee against the order of the Learned Principal Commissioner of Income Tax (Central), (hereinafter referred to as “the Ld.PCIT”), Chennai-1, dated 28.03.2025 for the Assessment Year (hereinafter referred to as "AY”) 2015-16 and order dated 26.03.2025 for AY 2016-17 exercising his revisional power u/s.263 of the Income Tax Act, 1961 (hereinafter referred to as "the Act”). Both sides agreed that the facts and issues involved in both the appeals are same and therefore, with the consent of both the parties, the facts pertaining to AY 2015-16 is taken as the lead case, result of which will be followed for AY 2016-17.

2. The brief facts pertaining to AY 2015-16 are that the assessment in the case of assessee’s trust was completed by the AO vide order dated 25.10.2017 u/s.143(3) of the Act without making any addition [original assessment]. Thereafter, pursuant to search conducted at the premise of Chettinad Builders [third party], the AO based on material found at the premises of Chettinad builders, recorded his satisfaction on 29.01.2022 for invoking action under Section 153C of the Act and consequently issued notice u/s.