ORDER

Per Renu Jauhri, Accountant Member:

The above captioned three appeals in ITA Nos. 6624, 6625 & 6626/Del/2025 are preferred by the assessees against the order dated 09.10.2025, passed by Ld. CIT(A)-25, New Delhi u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for A.Ys. 2014-15, 2015-16 & 2016-17, respectively.

2. The assessees has raised following grounds of appeal:

ITA No. 6624/Del/2025

“1. That having regard to the facts and circumstances of the case, ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in passing the impugned assessment order u/s 153C and that too without assuming jurisdiction as per law and without recording mandatory 'satisfaction' in accordance with law and without complying/following with the other mandatory conditions/procedure as laid down u/s 153C in accordance with law.

2. That in any case and in any view of the matter, action of ld. CIT(A) in confirming the action of Ld. AO in passing the impugned assessment order u/s 153C, is illegal, bad in law and against the facts and circumstances of the case and the same is not sustainable on various legal and factual grounds.

3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making addition of Rs.36,66,880/- by treating it as alleged unexplained money u/s 69A and that too without there being any incriminating material found as a result of search and by recording incorrect facts and findings and without following the principles of natural justice and without confronting the adverse material on record and without providing the opportunity of cross examination.

4. That in any case and in any view of the matter, action of ld. CIT(A) in confirming the action of Ld. AO in making addition of Rs.36,66,880/- u/s 69A, is bad in law and against the facts and circumstances of the case.

5. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making addition of Rs.21,117/- by treating it as alleged unexplained money u/s 69A and that too without there being any incriminating material found as a result of search and by recording incorrect facts and findings and without following the principles of natural justice and without confronting the adverse material on record and without providing the opportunity of cross examination.

6. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making addition of Rs.633/- by treating it as alleged unexplained expenditure u/s 69C and taxing the same u/s 115BBE and that too without there being any incriminating material found as a result of search and by recording incorrect facts and findings and without following the principles of natural justice and without confronting the adverse material on record and without providing the opportunity of cross examination.

7. That in any case and without prejudice to the above grounds, additions made in the impugned assessment order is beyond jurisdiction and illegal, also for the reason that such order could not have been made since no incriminating material has been found as a result of search.

8. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in passing the impugned assessment order dated 17-03-2024 without there being requisite approval in terms of section 153D and in any case approval, if any, is mechanical without application of mind and is no approval in the eyes of law.

9. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in passing the impugned assessment order dated 17-03-2024 which is barred by limitation.

10. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on