IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER AYs: (2014-15 to 2017-18)

Shri Vikas Agarwal, vs. ITO, D-103, Pramukh Garden Kilvani Naka, Silvassa Ward, Silvassa - 396230, Dadra and Nagar Silvassa Haveli (UT)

èथायीलेखासं./जीआइआरसं./PAN/GIR No: BCNPA1466N (Appellant) (Respondent)

Appellant by Shri Suresh K. Kabra, C.A.

Respondent by Shri Ravi Kant Gupta, CIT-DR Date of Hearing 31/07/2025 Date of Pronouncement 19/ 08/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM:

These appeals by the appellant emanate from the separate orders passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [in short, ‘CIT(A)’] for the assessment years (AYs) 2014-15 to 2017-18, which in turn arise out of separate assessment and penalty orders passed by the Assessing Officer (in short, ‘AO’). In all appeals, facts are common and grounds of appeal are similar. With the consent of both the parties, all appeals were clubbed, heard together and are decided by a common order for brevity and convenience. For appreciation of facts appeal in ITA No.186/SRT/2025 for AY-2014-15 is treated as ‘Lead case’.

2. The ground of appeal raised by the assessee in ITA No.186/SRT/2025 (AY 2014-15) is as under:

1. The Ld. CIT(A), NFAC, Delhi has erred and was not just and proper on the facts of the case and in law in confirming the addition of Rs.2,00,77,16,610/- u/s.69A of the Income tax Act.

3. The ground of appeal raised by assessee in ITA No. 187/SRT/2025 (AY

2014-15) is as under:

1. The Ld. CIT(A), NFAC, Delhi has erred and was not just and proper on the facts of the case and in law in confirming the penalty u/s.271(1)(c) of the Act.

4. The ground of appeal raised by appellant in ITA No.188/SRT/2025 for AY. 2015-16 is as under:

“1. The Ld CIT, NFAC has erred and was not just and proper on the facts of the case and in law on confirming the addition of Rs.10,79,500/- u/s 69A of the Income-tax Act.

2. the Ld CIT, NFAC has erred and was not just and proper on the facts of the case and in law in confirming the addition of Rs.8,76,22,375/- u/s 69A of the Income-tax Act.

3. PRAYER

3.1 The addition made by Ld Assessing Officer and confirmed by the Ld CIT(A)-

NFAC may be kindly deleted.

3.2 Personal hearing may be granted.

3.3 Any other relief that your honours may deem fit may be granted.

4. The appellant craves leave to add, amend, alter or delete any or all of the above grounds of appeals.”

5. The ground of appeal raised by appellant in ITA No.189/SRT/2025 for AY. 2015-16 is as under:

“1. The Ld Faceless Assessing Officer has erred and was not just and proper on the facts of the case and in law in confirming the Penalty u/s 271(1)(c).

2. PRAYER:

2.1 The penalty imposed may be kindly deleted.

2.2 Any other relief that your honours may deem fit may be granted.

3. The appellant craves leave to add, amend, alter or delete any or all of the above grounds of appeals.”

6. The ground of appeal raised by appellant in ITA No.190/SRT/2025 for AY. 2016-17 is as under:

“1. The Ld CIT, NFAC has erred and was not just proper on the facts of the case and in law in confirming the addition of Rs.8,14,01,800/- u/s 69A of the Income-tax Act. 2. The Ld CIT, NFAC has erred and was not just proper on the facts of the case and in law in confirming the addition of Rs.3,98,76,980/- u/s 69A of the Income-tax Act.

3. PRAYER:

3.1 The addition made by Ld Assessing Officer and confirmed by the Ld CIT(A) –

NFAC may be kindly deleted.

3.2 Personal hearing may be granted.

3.3 Any other relief that your honours may deem fit may be granted.

4. The appellant craves leave to add, amend, alter or delete any or all of the above grounds of appeals.”

7. The ground of appeal raised by appellant in ITA No.191/SRT/2025 for AY. 2016-17 is as under:

“1. The Ld Faceless Assessing Officer has erred and was not just and proper on the facts of the ca