ORDER

PER BENCH:

The cross appeals by the assessee and the Revenue have been filed against the separate impugned orders of even date 13.11.2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment years 2022-23 and 2023-24.

2. Since all the appeals pertained to the same assessee, involving similar issues arising out of a similar factual matrix, these appeals were heard together as a matter of convenience and are being decided by way of this consolidated order. With the consent of the parties, the cross appeal for the assessment year 2022-23 is considered as a lead case, and the decision rendered therein shall apply mutatis mutandis to the cross appeal for the assessment year 2023-24.

ITA No.781/Mum/2026

Revenue’s Appeal – A.Y. 2022-23

3. In this appeal, the Revenue has raised the following grounds: -

1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the disallowance of Rs.85,27,45,662/ - made by the Assessing Officer under section 36(1)(viia)(c) of the Income tax Act, 1961, without proper appreciatio