ORDER

PER BENCH:

The captioned appeals preferred by the revenue emanates from the respective orders of the Ld.CIT(Appeals)/NFAC, dated 27.01.2025 for the assessment years 2018-19 & 2019-20.

2. Since both the parties herein conceded that the facts and issues involved in both these appeals are substantially similar and identical, therefore, on hearing their submission, both these matters are heard together and disposed off vide this consolidated order.

3. That before proceeding for adjudication, it is also pertinent to mention here that the assessee had filed an application under Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963 which was later withdrawn by the assessee as evident from the order sheet entry dated 19.09.2025 for both the assessment years i.e. A.Ys. 2018-19 & 2019-20.

4. First, we would take up the appeal filed by the Revenue in ITA No.151/RPR/2025 for A.Y.2018-19 for adjudication wherein grounds of appeal raised by the Revenue are as follows:

“1. Whether on facts and in the circumstances of the case, the ld. CIT(A) was justified in deleting the addition of Rs.2,04,23,038/- which was added by the A.O?

2. Whether on facts and in the circumstances of the case, the ld