IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “B” BENCH: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

[Assessment Year: 2018-19, 2019-20 & 2020-21]

ORDER PER MANISH AGARWAL, AM:

The captioned appeals are filed by assessee against the separate orders, all are dated 10.03.2025 passed by Ld. Commissioner of Income Tax (A)-30, New Delhi [“Ld. CIT(A)”] u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment orders, all are dated 30.03.2023 passed u/s 153C r.w.s. 143(3) of the Act pertaining to Assessment Years 2018-19, 2019-20 & 2020-21 respectively. The details of the orders of ld. CIT(A) are tabulated as under:

details of the orders of ld. CIT(A) are tabulated as under:

details of the orders of ld. CIT(A) are tabulated as under:

details of the orders of ld. CIT(A) are tabulated as under:

details of the orders of ld. CIT(A) are tabulated as under:

2. As all the three captioned appeals filed by the assessee have similar issues which are inter-linked, inter-connected and this fact has been admitted by both the parties during the course of hearing before us, therefore, all the appeals filed by the assessee are decided by a common order.

3. First, we take the assessee’s appeal in ITA No.2227/Del/2025 for AY 2018-19.

ITA No. 2227/Del/2025 [Assessment Year: 2018-19]

4. Brief facts of the case are that the assessee e-filed her return of income on 31.08.2018, declaring total income of INR 9,87,793/-. A search and seizure operation was carried out at various premises of Shri Kuldeep Bishnoi Group and its associates on 23.07.2019. Various documents/books of accounts etc. were found and seized and statements of various persons were recorded. It was found that some incriminating material found and seized contained some entries related to the assessee. Subsequently, satisfactions were recorded by AO of the searched person and the documents alongwith the satisfaction note was handed over to the AO of the assessee. Thereafter the AO of the assessee recorded his satisfaction note on 03.12.2021 and initiated the proceedings u/s 153 of the Act for the assessment years 2014-15 to AY 2020-21 and, notice u/s 153C was issued on 06.12.2021. In compliance to the notice issued u/s 153C, the assessee filed return on 21.12.2021, declaring total income of INR 9,87,793/-. Thereafter, notice u/s 143(2) followed by statutory notices u/s 142(1) were issued alongwith detailed questionnaire from time to time to the assessee. After considering the submissions made and material furnished by the assessee, the AO assessed the income of the assessee at INR 58,29,693/- vide assessment order dated 30.03.2023 passed u/s 153C r.w.s. 143(3) of the Act wherein an addition of Rs. 48,41,900/- was made being GP @ 35% on the cash transactions of Rs. 1,38,34,000/- alleged as undisclosed sales.

5. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 10.03.2025, dismissed the appeal of the assessee.

6. Aggrieved by the order of Ld. CIT(A), assessee is in appeal before the Tribunal by taking following grounds of appeal:-

1. That on facts and in law, the impugned assessment order dated

30.03.2023 passed u/s. 153C r.w.s. 143(3) of the Income-tax Act, 1961 ("Act") for subject Assessment year 2018-19, making impugned addition therein of Rs.48,41,900/- ("First impugned order") and consequent impugned order dated 10.03.2025 passed by the Ld. Commissioner of Income-tax (Appeals) ("CIT(A)") u/s. 250(6) of the Act ("Second