O R D E R

Per Kavitha Rajagopal, JM:

The captioned appeals are filed by the Revenue challenging the order of the Learned Commissioner of Income Tax (Appeals) [‘Ld. CIT(A)’ for short], National Faceless Appeal Centre (‘NFAC’ for short) passed u/s 250 of the Income Tax Act, 1961 (“the Act” for short) relevant to assessment years (“AY” for short) 2011-12, 2012-13, 2013-14,& 2012-13.

2. The Revenue has challenged the order of the Ld. CIT(A) on deleting the following additions for the relevant AYs tabulated herein under:

3. As the facts are identical, we hereby pass a consolidated order by taking ITA No.2962/M/2024 for AY 2011-12 as a lead case for the sake of convenience.

4. The Revenue has raised the following grounds of appeal:

“1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the addition u/s 68 of the I.T. Act of Rs.27,36,17,764/ (on protective basis) when the Director of assessee company, Shri Lavekush Gadiya had accepted that assessee company have provided bogus accommodation entries to various entities, thereby the nature of transaction are non-genuine transactions?

2. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the addition u/s 68 of the I.T. Act of Rs.27,36,17,764/- (on protective basis), ignoring the facts and findings made by the investigation Wing and the fact that the assessee company failed to explain the source of the credit entries of Rs.27,36,17,764/-?

3. The appellant prays that the order of the CIT(A) on the grounds be set aside and confirm the order of the AO.

4. The appellant craves leave to add, amend or alter all or any of the grounds of appeal.”

5. Brief facts of the case are that the assessee company was a private limited company incorporated on 12.10.2009 under the Erstwhile Companies Act, 1956 in the name and style of Mega Money Commodities Pvt. Ltd. and had subsequently changed its name to Nirnay Commodities & Derivatives Pvt. Ltd. The assessee company e-filed its return of income dated 30.09.2011 declaring total income at Rs.5,530/- for the year under consideration and the same was processed u/s 143(1) of the Act. The assessee’s case was reopened u/s 147 of the Act vide notice u/s 148 of the Act dated 30.03.2018 for the reason that the assessee company was providing accommodation entries to various entities, as per the information received from Dy. Director of Income Tax (Inv.)-2, Indore and pursuant to the enquiries conducted where it was found that Shri Lavekush Gadiya, the director of the assessee company was providing accommodation entries to various parties/entities through his company where it was found that Rs.27,36,17,764/- was credited in several bank accounts of the assessee company which were subsequently transferred to various parties/entities alleged to be beneficiaries of such accommodation entries through cheques/RTGS. Notice u/s 148 & 142(1) of the Act were issued by the Ld. Assessing Officer (“Ld. AO” for short)but returned unserved with a remark “left”. Notice u/s 143(2) of the Act dated 19.12.2018 was issued to the assessee. The Ld. AO also issued notice u/s 133(6) of the Act to various banks specified in the report of the investigation wing of Indore. After duly considering the assessee’s submi