IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA Nos. 1244 to 1251/Ahd/2024 (Assessment Year: 2013-14 to 2020-21)

(Assessment Year: 2013-14 to 2020-21)

(Assessment Year: 2013-14 to 2020-21)

(Assessment Year: 2013-14 to 2020-21)

(Assessment Year: 2013-14 to 2020-21)

(Assessment Year: 2013-14 to 2020-21)

(Assessment Year: 2013-14 to 2020-21)

(Assessment Year: 2013-14 to 2020-21)

ITA No. 1233/Ahd/2024 (Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Assessment Year: 2020-21)

(Appellants) .. (Respondents Assessee represented by : Shri Vijay Mehta, AR Revenue represented by : Shri R.P. Rastogi, CIT DR Date of Hearing 12.01.2026 Date of Pronouncement 13.01.2026

O R D E R

PER BENCH:-

The appeals filed by the assessee for Assessment Years 2013–14 to 2020–21 arise out of a common consolidated order dated 26.04.2024 passed by the learned Commissioner of Income-tax (Appeals)-11, Ahmedabad Since the facts involved and the issues raised in all these appeals are common in nature and interlinked with each other, the appeals were heard together and are being disposed of by way of this common order for the sake of convenience and consistency.

2. We shall first deal with the appeal for Assessment Year 2013–14 as the lead year. The findings recorded for Assessment Year 2013–14 shall apply to the remaining assessment years also, unless specifically stated otherwise.

3. The assessee has raised the following Grounds of Appeal for assessment year 2013-14:

“1. The learned CIT(A) has erred in not holding that the notice issued u/s. 148 of the Act is bad in law, illegal and void-ab-initio. The learned CIT (A) has further erred in not holding that procedure as per law was not followed while issuing the notice u/s. 148 of the Act.

2. The learned CIT (A) has erred in not holding that the assessment order passed by AO u/s. 147 of the Act is bad in law, illegal and null and void.

3. The learned CIT(A) has erred in confirming the additions made by AO in the Appellant's case and rejecting the submissions that the noting in the seized diaries do not pertain to/belong to the Appellant.

4. The learned CIT(A) has erred in confirming the addition of Rs. 98,24,766/- made by the AO u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition.

5. The learned CIT(A) has erred in not holding that the assessment order passed by AO is in gross violation of principles of natural justice.

6. The Appellant states that the search proceedings carried out in his case are beyond jurisdiction, illegal and void. The consequential assessment order passed is bad-in-law, illegal and void-ab-initio.

7. The Appellant craves leave to add, amend and/ or alter the ground or grounds of appeal either before or at the time of hearing of the appeal.”

4. The brief facts of the case are that the assessee, Shri Mukesh Mohanlal Vaghela, an individual, filed his return of income for Assessment Year 2013–14 declaring a total income of ₹5,42,440/-, which was processed under section 143(1) of the Income-tax Act, 1961 (“the Act”). Subsequently, a search and seizure action under section 132 of the Act was conducted on 23.11.2021 in the case of Shri Prakash M. Sanghvi and other members and concerns of the Ratnamani Group. During the course of the said search, several handwritten diaries and loose papers marked as Annexure A-1 to A-12 were found and seized from the residential premises of Shri Prakash M. Sanghvi. In his statement recorded under section 132(4) of the Act, Shri Prakash M. Sanghvi categorically admitted that these diaries were maintained by