, , आयकर अपीलीय अिधकरण इंदौर (cid:586)ायपीठ इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M. JOSHI, JUDICIAL MEMBER ITA No. 727/Ind/2024 (AY:2013-14)

&

IT(SS)A Nos.87 to 91/Ind/2024 (AYs:2014-15 to 2018-19)

Bhargavi Keswani, बनाम/ ACIT (Central-II)

Olympus, Vs. Bhopal Opposite Forum Mall, Bengaluru (Assessee/Appellant) (Revenue/Respondent)

PAN:ANJPK5688C Assessee by Shri Hitesh Chimnani & Shri Yash Kukreja, ARs Revenue by Shri Anoop Singh, CIT-DR Date of Hearing 10.09.2025 Date of Pronouncement 26.09.2025 आदेश / O R D E R Per Bench:

The captioned six (6) appeals are filed by assessee against a single consolidated order of first-appeal dated 31.07.2024 passed by learned Commissioner of Income-tax (Appeals)-3, Bhopal [“CIT(A)”] which in turn arises out of a single consolidated assessment-order dated 16.07.2021 passed by DCIT, Central-II, Bhopal [“AO”] u/s 153A r.w.s 143(3) of the Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2013-14 to

2018-19.

2. The background facts leading to present appeals are such that a search u/s 132 was conducted by Income-tax authorities on 16.05.2018 on assessee pursuant to which the assessments of assessee for preceding six AYs 2013-14 to 2018-19 were framed u/s 153A r.w.s. 143(3) and assessment of AY 2019-20 relating to search-year was framed u/s 143(3) vide a consolidated assessment-order dated 16.07.2021. Presently in these appeals, we are concerned with preceding six AYs 2013-14 to 2018-19 wherein the AO completed assessments after making year-wise additions on account of assessee’s share in “cash collections” from project “Pebble Bay” done under a “Joint Venture Agreement (JVA)” entered by assessee with “M/s Amrit Homes Private Limited (AHPL)”and “M/s Amrit Coloniser Private Limited (ACPL)”. The AO has given year-wise working of additions on Page 13 of assessment-order in a tabular format. Aggrieved, the assessee carried matter in first-appeal and contested assessment-order on jurisdictional illegality as well as on merit but did not succeed. Now, the assessee has come in next appeal before us.

3. Since these appeals emanate from a single order of CIT(A) and identical grounds/facts/issues are involved; these all appeals were heard together at the request of parties and are being disposed of by this consolidated order for the sake of convenience, brevity and clarity.

4. The assessee has raised identical grounds in all six appeals. Hence, for reference purpose, we re-produce the effective grounds raised in first appeal of AY 2013-14 only:

“1. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in upholding the validity ofthe orderpassed by the Ld. AO under section 153A r.w.s. 143(3) of the Income Tax Act, 1961, which erroneous, withoutjurisdiction and bad-in-law.

2. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in confirming the addition u/s 69A of the Income Tax Act, 1961 without properly appreciating the facts of the case and the submissions made before him.

3. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in confirming the addition which was made without giving the assessee an adequate opportunity of cross examination, which is in violation ofprinciples ofnaturaljustice.”

Ground No. 1:

5. In this ground, the assessee claims that the assessment framed by AO u/s 153A is erroneous, without jurisdiction and bad in law.

6. During hearing, Ld. AR submitted that although the assessee has raised this ground in all six years but the assessee is pressing it for first four AYs 2013-14 to 2016-17 only. There was some discussion about AY 2014-15 whose return of income was not filed by assessee u/s 139 and the Ld. AR desired to take a call for this assessment-year and intimate to bench. After hearing, Ld. AR has filed a letter accepting that the assessee has finally decided to press Ground No. 1 in three AYs 2013-14,