ORDER

PER SANDEEP GOSAIN:

The present appeals have been filed by the Revenue and cross objection by the assessee challenging the different impugned orders dt. 09.06.2025 and 10.06.2025 passed under section 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) /CIT(A) for the assessment year 2013-14 and 2014-15.

2. Since all the issues involved in these appeals and cross objection are common and identical and belongs to one assessee therefore, they have been clubbed, heard together and consolidated order is being passed.

Firstly, we shall take ITA No. 5307/Mum/2025, A.Y 2013-14 as lead case and facts narrated therein.

The Revenue has raised the following grounds of appeal:

1. Whether the Ld. CIT(A) erred in law and on facts in deleting the addition of Rs. 21,06,50,000/- made under Section 68 of the Income Tax Act, 1961, without properly appreciating that the assessee failed to establish the creditworthiness of M/s Startree Dealer Pvt. Ltd., from whom the amount was received in A.Y. 2013-14?

2. Whether the Ld. CIT(A) was justified in holding that the receipt was a deferred sale consideration for a transaction disclosed in an earlier assessment year, despite the fact that no supporting documentary evidence such as bank statements, financials, or confirmations for A.Y. 2013-14 were produced to substantiate the claim?

3. Whether the Ld. CIT(A) erred in ignoring the investigation findings in the case of M/s Sukalyan Complex Put. Ltd., which identified M/s Startree Dealer Put. Ltd. as an accommodation entry provider, thereby casting serious doubt on the genuineness and source of the receipt shown by the assessee?

4. Whether the Ld. CIT(A) erred in law in deleting the addition merely on the basis of a prior transaction assessment without independently verifying the genuineness and source of the actual receipt during the year under appeal?

5. The appellant craves leave to add, alter, amend or withdraw any of the above grounds at the time of hearing. "

3. All the grounds raised by the Revenue are interrelated and interconnected and relates to challenging the order of the Ld. CIT(A) in deleting the additions made by the AO under Section 68 of the Act. Therefore, we have decided to adjudicate these grounds through the present consolidated order.

4. The Ld. DR, appearing on behalf of the Revenue, while relying upon the order of assessment, submitted that the Ld. CIT(A) erred in deleting the additions without properly appreciating that the assessee failed to establish the creditworthiness of M/s. Startree Dealers Pvt. Ltd., from whom the amount was received in the year under consideration. It was further submitted that the Ld. CIT(A) had also wrongly held that the receipts were deferred sale consideration for a transaction disclosed in an earlier assessment year, despite the fact that no supporting documentary evidence such as bank statements, financials, or confirmations for the year under consideration were produced to substantiate the same. The Ld. DR further submitted that the Ld. CIT(A) ignored the investigation findings in the case of M/s. Sukalyan Complex Pvt. Ltd., which identified M/s. Startree Dealers Pvt. Ltd. as an accommodation entry provider, thereby casting serious doubts on the genuineness and source of the receipts shown by the assessee.

5. Whereas, on the contrary, the Ld. AR appearing on behalf of the assessee relied upon the order passed by the Ld. CIT(A) and also his written submissions filed before us, the same is reproduced herein below:

The grounds taken up by the Department is not sustainable as CIT (A) has examined the facts and has made clear findings supported by legal decisions.

1. Whether the Ld. CIT (A) erred in law and on facts in deleting the addition of Rs.21,06,50,000/- made under Section 68 of the Income Tax Act, 1961, without properly appreciating that the assessee failed to establish the creditworthiness of M/s. Startree Dealer Pvt. Ltd., from whom the amount was received in A.Y. 2