IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI. KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.51& 52/Bang/2024 Assessment year : 2015-16, 2016-17 M/s. Global Stars Indmetal Pvt. Ltd., Vs. DCIT, 1-276, Pulkeri, Karkala, Central Circle - 1, Karnataka – 574 104. Mangalore.

PAN : AAFCG 5927 N APPELLANT RESPONDENT Appellant by : Smt. Sheetal Borker, Advocate Respondent by : Shri Subramanian S, JCIT(DR)(ITAT), Bengaluru.

Date of hearing : 23.04.2025 Date of Pronouncement : 30.04.2025

O R D E R

Per Laxmi Prasad Sahu, Accountant Member These two appeals by assessee are against the order of ld. CIT(A)-II Panaji dated 22.11.2023 with regard to addition of Rs.15 lakhs in the AY 2015-16 & Rs.40 lakhs in the AY 2016-17. Since the issue in these appeals is common and hence these are clubbed together heard together and disposed of by this common order for the sake of convenience.

2. The first common ground in these appeals is with regard to reopening of assessment u/s 147 of the Income Tax Act, 1961 (in short “The Act”).

3. Next ground is with regard to addition of Rs.40 lakhs. Facts of the case are that during the course of survey, materials c