O R D E R

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-

The captioned two appeals have been filed by the Assessee against the orders passed by the National Faceless Appeal Centre, vide orders both dated 19.11.2025 for the Assessment Years 2022-23 and 2023-23. Since the issues involved in both the appeals are common and identical, we extract the grounds of appeal raised in ITA No.302/Ahd/2026 for Assessment Year 2022-23 for the purpose of adjudication. The decision rendered in the said appeal shall apply mutatis mutandis to the other appeal bearing ITA No. 303/Ahd/2026 for Assessment Year 2023-24.

2. The Assessee has taken the following ground of appeal:-

1.0 The learned Commissioner of Income Tax (Appeals), NFAC has erred in law and on facts in confirming the addition of ₹1.84,16,10,000/- on account of Capital Grants, Subsidies and Consumers Contribution by arbitrarily holding that 15% of the total grants/subsidies/consumer contribution received during the year is required to be transferred, as against 5.28% offered by the appellant, without appreciating the correct accounting treatment, factual matrix and settled position in the appellant's own case

1.1 The learned Commissioner (Appeals)