O R D E R

Per Sanjay Garg, Judicial Member:

The captioned four appeals have been preferred by the assessee against the separate orders of Ld. Commissioner of Income Tax Appeals, Jaipur-5 (hereinafter referred to as “Ld. CIT(A)”) all dated 29.08.2025 u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “Act”). Since facts and issues involved in all these appeals are common and identical, hence these have been heard together and are being disposed of by this common order. ITA No.1231/JPR/20025 for AY 2013-14 is taken as the lead case.

The assessee in this appeal have taken the following Grounds of Appeal:

“1. In the facts and circumstances of the case and in law, Id. CIT(A) has erred in confirming the jurisdiction assumed by the Id. AO in the case of the assessee, under Section 153C the Income Tax Act, 1961 ("ITA"). The action confirmed by ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by quashing the entire order, being illegal and void-ab-initio.

2. In the facts and circumstances of the case and in law, Id. CIT(A) has erred in confirming jurisdiction, in the case of the assessee, under Section 153C of the ITA, for the year under consideration, even though the case of the assessee was barred by limitation as per law, for proceedings initiated under Section 153C. The action confirmed by Id. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief, please be granted by quashing the entire order, passed under Section 153C, being illegal, void-ab-initio and barred by limitation.

3. In the facts and circumstances of the case and in law, Id. CIT(A) has erred in confirming the issuance of notice, in the case of the assessee, under Section 153C of the ITA, for the year under consideration, without recording proper satisfaction as required under the law. The action confirmed by Id. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief, please be granted by quashing the entire order, passed under Section 153C, being illegal and void-ab-initio.

4. In the facts and circumstances of the case and in law, Id. CIT(A) has erred in confirming the order passed in the case of the assessee, under Section 153C of the ITA, without providing a copy of the satisfaction note, as recorded by the Assessing Officer of the searched person, pursuant to which jurisdiction was assumed in the case of the assessee under Section 153C. The action confirmed by ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief, please be granted by quashing the entire order, passed under Section 153C, being illegal and void-ab-initio.

5. In the facts and circumstances of the case and in law, Id. CIT(A) has erred in confirming the notice issued in the case of the assessee, under Section 153C, in October 2023, whereas, the fact remains that search in the case of Shri Ramesh Manihar, being the searched person, had taken place in January, 2016. Accordingly, after lapse of more than 7.5 years from the time search was conducted in the case of Shri Ramesh Manihar, jurisdiction was assumed in the case of the assessee, under Section 153C, which renders the present proceedings being barred by limitation. The action confirmed by Id. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief, please be granted by quashing the entire order, passed under Section 153C, being illegal and void-ab-initio.

6. In the facts and circumstances of the case and law, Id. CIT(A) has erred in confirming the addition of Rs. 3,00,00,000, under Section 69A, on account of alleged unaccounted loans. The action confirmed by Id. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by deleting the entire addition of Rs. 3,00,00,000.

7. In the facts and circumstances of the case and law, Id. CIT(A) has erred in confirming the addition of Rs. 16,00,000 on account of interest on