IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR.

BEFORE SH. MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER AND SH. UDAYAN DASGUPTA, JUDICIAL MEMBER (Physical Hearing)

I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 and 2017-18 Assessment Years: 2014-15 and 2017-18 Assessment Years: 2014-15 and 2017-18 Assessment Years: 2014-15 and 2017-18 Assessment Years: 2014-15 and 2017-18 Appellant by Sh. Ashray Sarna, CA Respondent by Sh. Sunil Gautam, CIT. DR Date of Hearing 16.12.2025 Date of Pronouncement 15.01.2026

ORDER

Per: Udayan Dasgupta, J.M.:

Both these appeals are filed by the revenue against the orders of ld. CIT (A), NFAC, Delhi, passed u/s 250 of the Income Tax Act, 1961,( henceforth the Act ) both dated 29.01.2024 , which has emanated from the orders of AO, Circle Ferozepur, dated 30.12.2019 passed u/s 143(3) r.w.s. 147 of the Act (for A.Y. 2014-

15) and order dated 28.12.2019 passed u/s 143(3) of the Act ( for AY 2017-18 ).

2. The facts and issues contained in both the years being identical, are taken up for disposal together for the sake of convenience and we take up ITA No.

103/Asr/2024, first.

3. ITA No.103/Asr/2024:

The grounds taken by the revenue in Form no. 36 are