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2026 Supreme(Online)(ITAT) 3173

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Narender Kumar Choudhry, Judicial Member, Prabhash Shankar, Accountant Member
Pinkydevi Mahendrakumar Jain – Appellant
Versus
ACIT Central Circle 4(2) – Respondent


Advocates:
For the Appellants/Petitioners: Shri Vimal Punmiya, CA
For the Respondents: Shri R A Dhyani, (CIT DR)

Table of Content
1. consolidated appeals on identical facts heard together. (Para 1 , 2)
2. addition based on third-party search evidence and statements. (Para 3 , 4 , 5)
3. parties' contentions and initial tribunal observations. (Para 6 , 7)
4. addition deleted following coordinate bench precedents. (Para 8 , 9)

ORDER

Per : Narender Kumar Choudhry, Judicial Member:

These appeals have been preferred by the Assessee against the composite orders dated 22.08.2025 and 13.08.2025 qua Pinkydevi Mahendrakumar Jain and Pushpa Vikas Jain respectively, impugned herein, passed by Ld. Commissioner of Income Tax (Appeals) (in short Ld. Commissioner) u/s 250 of the Income Tax Act, 1961 (in short ‘the Act’) for the A.Y. 2019-20 and 2020-21.

2. As these appeals under consideration are having involved identical facts and issues, except variation in amounts and therefore, for the sake of brevity and convenience, the same were heard together and are being disposed of by this composite order by taking into consideration ITA No. 7095/M/2025 as the lead case, the result thereof shall apply mutatis mutandis to all the appeals under consideration.

3. Coming to ITA No. 7095/M/2025, it is observed that, on the basis

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