आदे श / ORDER

PER. RAVISH SOOD, JM :

The captioned cross-appeals filed by the assessee and the revenue are directed against the order passed by the CIT(Appeals) for AY 2017-18, dated 17/03/2025, which in turn arises from the order passed by the AO under Section 153C of the Act, dated 30/03/2022. As the present appeals involve common issues, they are taken up and disposed of together. The revenue has assailed the CIT(A) order on the following grounds of appeal before us:

“1. The order of Ld. CIT(A) is erroneous both on the facts and in Law.

2. The Ld. CIT(A) erred in summarily allowing the appeal of the assessee on sole ground of non-admissible seized material evidence used by the Assessing Officer during the assessment proceedings u/s.153C, consequent to search action conducted in the case of M/s. Polisetty Somasundaram group.

3.. The Ld. CIT(A) erred in giving a finding that the pen drive seized from the business premises of M/s Polisetty Somasundaram group and marked as Annexure A/PSS/CORP/19 was an inadmissible digital evidence as held by Hon'ble ITAT in the case of M/s Polisetty Somasundaram and hence the same can't be considered as a valid digital evidence in the case of the a