IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील स.ं / ITA Nos.1249 to 1252/PUN/2024 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Assessment Years : 2013-14, 2014-15, and 2015-16 Appellant by : Shri Pramod S Shingte Respondent by : Shri Amol Khairnar Date of hearing : 17.12.2025 Date of pronouncement : 28.01.2026 आदेश / ORDER PER DR. MANISH BORAD, ACCOUNTANT MEMBER :

The captioned appeals at the instance of assessee pertaining to A.Yrs. 2013-14, 2014-15 and 2015-16 are directed against the separate orders dated 25.04.2024 and 26.04.2024 framed by National Faceless Appeal Centre, Delhi (NFAC) arising out of respective assessment orders/penalty orders passed u/s.143(3)/271(1)(c) of the Act.

2. Identical grounds have been taken by the assessee in most of these appeals, therefore, these appeals were heard together and are being disposed of by this consolidated order for the sake of convenience.

3. Firstly we will take up ITA Nos. 1249, 1251 and 1252/PUN/2024 in which assessee has raised some common grounds and the same are reproduced below :

“Grounds in ITA No.1249/PUN/2024 :

1. On the basis of facts and in the circumstances of the case, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of agricultural income of Rs. 99,643/-made u/s. 68 of the Act. The CIT(A) is not justified in rejecting the claim of the appellant of agricultural income for the incorrect reason that the appellant was not having any agricultural land, particularly when there was no dispute as regards the possession of agricultural land by the appellant and more particularly when the appellant has furnished copies of 7/12 extracts of the agricultural lands.

2. On the basis of facts and in the circumstances of the case, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.6,00,00,000/- made by the AO u/s.68 of the Act.

3. On the basis of the facts and in the circumstances of the case and as per law, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.6,00,00,000/- u/s. 68 of the Act made by A.O. without confronting the material on the basis of which, the impugned addition is confirmed by the CIT(A).

4. The appellant craves for the addition to, deletion, alteration, modification of the above grounds of appeal.

Grounds in ITA No.1251/PUN/2024 :

“1. On the basis of facts and in the circumstances of the case, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.82,50,000/- made by the AO u/s. 68 of the Act.

2. On the basis of the facts and in the circumstances of the case and as per law, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs. 82,50,000/- u/s. 68 of the Act made by A.O. without confronting the material on the basis of which, the impugned addition is confirmed by the CIT(A).

3. The appellant craves for the addition to, deletion, alteration, modification of the above grounds of appeal.”

Grounds in ITA No.1252/PUN/2024 :

1. On the basis of facts and in the circumstances of the case, the Commissioner of Income Tax (Appeals) is not justified Rs. in confirming the addition of Rs.3,13,50,000/ made by the AO u/s.

68 of the Act.

2. On the basis of the facts and in the circumstances of the case and as per law, the Commissioner of Income Tax (Appeals) is not justified in confirming the addition of Rs.3,13,50,000/- u/s.68 of the Act made by A.O. without confronting the material on the basis of which, the impugned addition is confirmed by the CIT(A).

3. On th