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0 BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI GAGAN GOYAL, AM vk;dj vihy la-@ITA Nos.1520 & 1525/JPR/2024 fu/kZkj.k o"kZ@AssessmentYear :2015-16 & 2017-18 The DCIT cuke Madhu Chordia Central Circle-3, Vs. C-61, Sangram Colony, Jaipur C-Scheme, Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: ABEPC3321R vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Sh. Vinod Gupta, CA jktLo dh vksjls@Revenue by :Sh. Arvind Kumar, CIT-DR lquokbZ dh rkjh[k@Date of Hearing :17/03/2025 mn?kks"k.kk dh rkjh[k@Date of Pronouncement: 06/05/2025 vkns'k@ORDER PER: DR. S. SEETHALAKSHMI, J.M.

By way of present appeals, the revenue challenges the finding of the learned Commissioner of Income Tax (Appeal), Jaipur-4 dated 17.10.2024 [here in after ld. CIT(A)] for assessment years 2015-16 & 2017-18. The said orders of the ld. CIT(A) arise against the orders dated 30.05.2022 passed under section 143(3) r.w.s 153A of the Income Tax Act,1961 [ for short Act ] by ACIT, Central Circle-3, Jaipur [ for short AO]. As the issue involved in both the appeals is common, we deem it fit to dispose off these appeals by this common order.

2. In ITA No. 1520/JPR/2024, the Revenue has raised following grounds: -

“1. Whether in the facts and circumstances of the case and in law, the ld.CIT (A) is justified in deleting the addition of Rs.3,30,00,000/-u/s69 made by the AOon account of undisclosed income disregarding the facts that the addition was based on the incriminating material found and seized in the laptop and there remains no use of physical copy of agreement after execution of registered deed which is general practice in property transactions.

2. The appellant craves leave or reserves right to amend, modify, alter, add or forgo any grounds) of appeal at any time before or during the hearing of appeal.”

Whereas in ITA No. 1525/JPR/2024, it has raised following grounds: -

“1. Whether in the facts and circumstances of the case and in law, the ld.CIT (A) is justified in deleting the addition of Rs.2,45,65,000/- u/s 69 made by the AO on account of undisclosed income disregarding the facts that the addition was based on the incriminating material found and seized in the laptop and there remains no use of physical copy of agreement after execution of registered deed which is general practice in property transactions.

2. The appellant craves leave or reserves right to amend, modify, alter, add or forgo any grounds) of appeal at any time before or during the hearing of appeal.”

3. As the issue involved in both the appeals is common, we deem it fit to dispose it off by this common order. We are taking ITA No.1520/JP/2024 as the lead case.Succinctly, the fact as culled out from the records is that a search & seizure operation under section 132(1) of the Income Tax Act, 1961 (hereinafter ‘the Act’) was carried out on 19.01.2021in the case of “Chordia Group” to which the assessee belongs. Consequent to search action, the case of the assessee was centralized to ACIT, Central Circle-3, Jaipur by the Principal Commissioner of Income-tax, Jaipur-2 vide his order dated 28.07.2021.

3.1 Assessee is an individual and had filed her return of income u/s 139 of the Act on 28.03.2016 declaring total income of Rs. 26,91,090/-. Consequent to notice u/s 153A of the Act was issued on 22.10.2021 and in compliance thereto, return was filed on 22.12.2021 declaring total income of Rs. 12,32,390/-. Statutory notices were issued and served upon the assessee calling for the details and the assessee in response to those notice furnished the details / information / documents / which were examined with respect to claims made in the return of income. Subsequently, order u/s 153A of the Act was passed on 30.05.2022 wherein addition of Rs. 3,30,00,000/- was made alleging undisclosed investment u/s 69 of the Act by the respo