IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2014-15 & 2015-16]

Surya Roshni Limited, vs Pr.CIT-7, 2nd Floor, Padma Tower-1, Delhi Rajendra Place, New Delhi-110008. PAN-AAACS3558C APPELLANT RESPONDENT Appellant by Shri Akshat Jain, CA &

Shri Rajat Jain, CA Respondent by Shri Mahesh Kumar, CIT DR Date of Hearing 04.06.2025 Date of Pronouncement 28.08.2025 ORDER PER MANISH AGARWAL, AM :

The captioned appeals are filed by the assessee against two separate orders, both dated 26.03.2024 passed by Ld. Pr. Commissioner of Income Tax, Delhi [“Ld. Pr. CIT”] passed u/s 263 of the Income Tax Act, 1961 [“the Act”] arising from the different assessment orders dated 14.03.2022 and 11.03.2022 passed u/s 147 r.w.s. 143(3) of the Act for Assessment Years 2014-15 & 2015-

16 respectively.

2. At the time of hearing, it was stated that the issues involved for Assessment Years 2014-15 to 2015-16 are common, interlinked and identical. Hence, both appeals have been heard together and accordingly, adjudicated by this common order.

ITA No.1445/Del/2024 [Assessment Year 2014-15]

3. Brief facts o