ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, DELHI, DELHI vs. PRATYAKSH APPARELS PRIVATE LIMITED, DELHI
In favour of the Revenue: the Revenue's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.
What were the facts?
The appeals involved assessments framed under Section 153C of the Income Tax Act, 1961. The core issue was the validity of these assessments due to alleged lack of incriminating material and improper satisfaction recorded by the Assessing Officer.
What were the issues?
Whether the satisfaction recorded by the Assessing Officer for initiating proceedings under Section 153C was valid and whether the seized material had a bearing on the determination of the assessee's total income.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: ‘E’ NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI M. BALAGANESH
Heard together (32 matters)
Read from the judgment's own cause title. This page is filed under one of them.
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER
ITA No.5378/Del/2025 along with C.O. No.205/Del/2026 Assessment Year: 2011-12 With ITA No.5379/Del/2025 along with C.O. No.206/Del/2026 Assessment Year: 2012-13 With ITA No.5380/Del/2025 along with C.O. No.207/Del/2026 Assessment Year: 2013-14 With ITA No.5381/Del/2025 along with C.O. No.208/Del/2026 Assessment Year: 2014-15 With ITA No.5382/Del/2025 along with C.O. No.209/Del/2026 Assessment Year: 2015-16 With ITA No.5383/Del/2025 along with C.O. No.210/Del/2026 Assessment Year: 2016-17 With ITA No.5384/Del/2025 along with C.O. No.211/Del/2026 Assessment Year: 2017-18 With ITA No. 6149/Del/2025 ; Assessment Year: 2015-16 With ITA No. 6927/Del/2025 ; Assessment Year: 2018-19
ACIT, Vs. Anmol Tradex Pvt Ltd. Central Circle-25, F-3, 1st Floor, TDI Fun New Delhi Republic Mall, Moti Nagar, New Delhi- 110 015 PAN: AAHCA5444J (Appellant) (Respondent/Cross-objector)
ITA No. 8051 to 8057/Del/2025; Assessment Years: 2013-14 to 2019-20 Vs. Pratyaksh ACIT, Apparels Private Central Circle-25, Limited New Delhi H-84, 1st Floor, Shivaji Park, Delhi- 110026 PAN: AADCP5737H (Appellant) (Respondent/Cross-objector) ITA No.5385/Del/2025 along with C.O. No.212/Del/2026 Assessment Year: 2011-12 With ITA No.5386/Del/2025 along with C.O. No.213/Del/2026 Assessment Year: 2012-13 With ITA No.5387/Del/2025 along with C.O. No.214/Del/2026 Assessment Year: 2013-14 With ITA No.5388/Del/2025 along with C.O. No.215/Del/2026 Assessment Year: 2014-15 With ITA No.5389/Del/2025 along with C.O. No.216/Del/2026 Assessment Year: 2015-16 With ITA No.5390/Del/2025 along with C.O. No.217/Del/2026 Assessment Year: 2016-17 With ITA No.5391/Del/2025 along with C.O. No.218/Del/2026 Assessment Year: 2017-18 With ITA No. 6981/Del/2025 ; Assessment Year: 2018-19 With ITA No. 6150/Del/2025 ; Assessment Year: 2018-19 Vs. Bal ACIT, Gopal Importers & Central Circle-25, Exporters Private Limited New Delhi WZ-106/141, Rajouri Garden Extension, New Delhi- 110 027 PAN: AADCB6901B (Appellant) (Respondent/Cross-objector) 2 | P a g e
Assessee by Dr. Manas Shankar Ray, Adv. Ms. Neelu Mohan, Adv. Shri Shashwat Saxena, Adv. Department by Shri Raghunath, CIT(DR)
Date of hearing 01.07.2026 Date of pronouncement 16.07.2026
ORDER PER BENCH: The instant batch of 39 cases involves the three assessees herein i.e., M/s Anmol Tradex Pvt. Ltd, M/s Bal Gopal Importers and Exporters Pvt. Ltd. & M/s Pratyaksh Apparels Pvt. Ltd. All other remaining details thereof stand tabulated (taxpayer-wise) as under:
Sl. Appeal No. Appellant Respondent Order Appealed against No. (Cross-Objector) 1-2 ITA ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order No.5378/Del/ Circle-25, Ltd. dated 27.05.2025 having 2025 along New Delhi F-3, 1st Floor, TDI DIN & Order No. with C.O. Fun Republic Mall, ITBA/APL/3/250/2025- No.205/Del/2 Moti Nagar, New 26/1076488841(1) involving 026 Delhi- 110 015 proceedings under Section Assessment 153C r.w.s. 143(3) of the Year: 2011-12 Act.
3-4 ITA ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order No.5379/Del/ Circle-25, Ltd. dated 27.05.2025 having 2025 along New Delhi F-3, 1st Floor, TDI DIN & Order No. with C.O. Fun Republic Mall, ITBA/APL/S/250/2025- No.206/Del/2 Moti Nagar, New 26/1076488814(1) involving 026 Delhi- 110 015 proceedings under Section Assessment 153C r.w.s. 143(3) of the Year: 2012-13 Act. 5-6 ITA ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order No.5380/Del/ Circle-25, Ltd. dated 27.05.2025 having 2025 along New Delhi F-3, 1st Floor, TDI DIN & Order No. with C.O. Fun Republic Mall, ITBA/APL/3/250/2025- No.207/Del/2 Moti Nagar, New 26/1076488082(1) involving 026 Delhi- 110 015 proceedings under Section
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Assessment 153C r.w.s. 143(3) of the Year: 2013-14 Act. 7-8 ITA ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order No.5381/Del/ Circle-25, Ltd. dated 27.05.2025 having 2025 along New Delhi F-3, 1st Floor, TDI DIN & Order No. with C.O. Fun Republic Mall, ITBA/APL/3/250/2025- No.208/Del/2 Moti Nagar, New 26/1076488212(1) involving 026 Delhi- 110 015 proceedings under Section Assessment 153C r.w.s. 143(3) of the Year: 2014-15 Act. 9-10 ITA ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order No.5382/Del/ Circle-25, Ltd. dated 27.05.2025 having 2025 along New Delhi F-3, 1st Floor, TDI DIN & Order No. with C.O. Fun Republic Mall, ITBA/APL/3/250/2025- No.209/Del/2 Moti Nagar, New 26/1076488356(1) involving 026 Delhi- 110 015 proceedings under Section Assessment 153C r.w.s. 143(3) of the Year: 2015-16 Act. 11-12 ITA ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order No.5383/Del/ Circle-25, Ltd. dated 27.05.2025 having 2025 along New Delhi F-3, 1st Floor, TDI DIN & Order No. with C.O. Fun Republic Mall, ITBA/APL/3/250/2025- No.210/Del/2 Moti Nagar, New 26/1076488483(1) involving 026 Delhi- 110 015 proceedings under Section Assessment 153C r.w.s. 143(3) of the Year: 2016-17 Act. 13-14 ITA ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order No.5384/Del/ Circle-25, Ltd. dated 27.05.2025 having 2025 along New Delhi F-3, 1st Floor, TDI DIN & Order No. with C.O. Fun Republic Mall, ITBA/APL/3/250/2025- No.211/Del/2 Moti Nagar, New 26/1076487879(1) involving 026 Delhi- 110 015 proceedings under Section Assessment 153C r.w.s. 143(3) of the Year: 2017-18 Act. 15 ITA No. ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order 6149/Del/202 Circle-25, Ltd. dated 27.05.2025 having 5 ; Assessment New Delhi F-3, 1st Floor, TDI DIN & Order No. Year: 2015-16 Fun Republic Mall, ITBA/APL/3/250/2025-26/ Moti Nagar, New 1078239982(1) involving Delhi- 110 015 proceedings under Section 153C r.w.s. 143(3) of the Act. 16 ITA No. ACIT, Central Anmol Tradex Pvt CIT(A), Delhi’s-31’s order 6927/Del/202 Circle-25, Ltd. dated 27.05.2025 having 5 ; Assessment New Delhi F-3, 1st Floor, TDI DIN & Order No. Year: 2018-19 Fun Republic Mall, ITBA/APL/3/250/2025- Moti Nagar, New 26/1078230982(1) involving Delhi- 110 015 proceedings under Section 153C r.w.s. 143(3) of the Act.
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17 ITA No. 8051 ACIT, Central Pratyaksh Apparels CIT(A), Delhi’s-31’s order /Del/2025; Circle-25, Private Limited dated 05.08.2025 involving Assessment New Delhi H-84, 1st Floor, proceedings under Section Years: 2013-14 Shivaji Park, Delhi- 153C r.w.s. 260 of the Act. 110026 18 ITA No. ACIT, Central Pratyaksh Apparels CIT(A), Delhi’s-31’s order 8052/Del/202 Circle-25, Private Limited dated 05.08.2025 involving 5; New Delhi H-84, 1st Floor, proceedings under Section Assessment Shivaji Park, Delhi- 153C r.w.s. 260 of the Act. Years: 2014-15 110026 19 ITA No. ACIT, Central Pratyaksh Apparels CIT(A), Delhi’s-31’s order 8053/Del/202 Circle-25, Private Limited dated 05.08.2025 involving 5; New Delhi H-84, 1st Floor, proceedings under Section Assessment Shivaji Park, Delhi- 153C r.w.s. 260 of the Act. Years: 2015-16 110026 20 ITA No. 8054 ACIT, Central Pratyaksh Apparels CIT(A), Delhi’s-31’s order /Del/2025; Circle-25, Private Limited dated 05.08.2025 involving Assessment New Delhi H-84, 1st Floor, proceedings under Section Years: 2016-17 Shivaji Park, Delhi- 153C r.w.s. 260 of the Act. 110026 21 ITA No. 8055 ACIT, Central Pratyaksh Apparels CIT(A), Delhi’s-31’s order /Del/2025; Circle-25, Private Limited dated 05.08.2025 involving Assessment New Delhi H-84, 1st Floor, proceedings under Section Years: 2017-18 Shivaji Park, Delhi- 153C r.w.s. 260 of the Act. 110026 22 ITA No. ACIT, Central Pratyaksh Apparels CIT(A), Delhi’s-31’s order 8056/Del/202 Circle-25, Private Limited dated 05.08.2025 involving 5; New Delhi H-84, 1st Floor, proceedings under Section Assessment Shivaji Park, Delhi- 153C r.w.s. 260 of the Act. Years: 2018-19 110026 23 ITA No. ACIT, Central Pratyaksh Apparels CIT(A), Delhi’s-31’s order 8057/Del/202 Circle-25, Private Limited dated 05.08.2025 involving 5; New Delhi H-84, 1st Floor, proceedings under Section Assessment Shivaji Park, Delhi- 153C r.w.s. 260 of the Act. Years: 2019-20 110026 24-25 ITA ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order No.5385/Del/ Circle-25, Importers & dated 27.05.2025 involving 2025 along New Delhi Exporters Private proceedings under Section with C.O. Limited 153C r.w.s. 143(3) of the No.212/Del/2 WZ-106/141, Act. 026 Rajouri Garden Assessment Extension, New Year: 2011-12 Delhi- 110 027 26-27 ITA ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order No.5386/Del/ Circle-25, Importers & dated 27.05.2025 involving 2025 along New Delhi Exporters Private proceedings under Section with C.O. Limited 153C r.w.s. 143(3) of the No.213/Del/2 WZ-106/141, Act. 026 Rajouri Garden Assessment Extension, New Year: 2012-13 Delhi- 110 027 28-29 ITA ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order No.5387/Del/ Circle-25, Importers & dated 27.05.2025 involving 2025 along New Delhi Exporters Private proceedings under Section with C.O. Limited 153C r.w.s. 143(3) of the Act. 5 | P a g e
No.214/Del/2 WZ-106/141, 026 Rajouri Garden Assessment Extension, New Year: 2013-14 Delhi- 110 027 30-31 ITA ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order No.5388/Del/ Circle-25, Importers & dated 27.05.2025 involving 2025 along New Delhi Exporters Private proceedings under Section with C.O. Limited 153C r.w.s. 143(3) of the No.215/Del/2 WZ-106/141, Act. 026 Rajouri Garden Assessment Extension, New Year: 2014-15 Delhi- 110 027 32-33 ITA ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order No.5389/Del/ Circle-25, Importers & dated 27.05.2025 involving 2025 along New Delhi Exporters Private proceedings under Section with C.O. Limited 153C r.w.s. 143(3) of the No.216/Del/2 WZ-106/141, Act. 026 Rajouri Garden Assessment Extension, New Year: 2015-16 Delhi- 110 027 34-35 ITA ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order No.5390/Del/ Circle-25, Importers & dated 27.05.2025 involving 2025 along New Delhi Exporters Private proceedings under Section with C.O. Limited 153C r.w.s. 143(3) of the No.217/Del/2 WZ-106/141, Act. 026 Rajouri Garden Assessment Extension, New Year: 2016-17 Delhi- 110 027 36-37 ITA ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order No.5391/Del/ Circle-25, Importers & dated 27.05.2025 involving 2025 along New Delhi Exporters Private proceedings under Section with C.O. Limited 153C r.w.s. 143(3) of the No.218/Del/2 WZ-106/141, Act. 026 Rajouri Garden Assessment Extension, New Year: 2017-18 Delhi- 110 027 38 ITA No. ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order 6981/Del/202 Circle-25, Importers & dated 07.07.2025 passed in 5 ; Assessment New Delhi Exporters Private DIN & Order No. Year: 2018-19 Limited ITBA/APL/S/250/2025- WZ-106/141, 26/1078245237(1),involvin Rajouri Garden g proceedings under Section Extension, New 153C r.w.s. 143(3) of the Delhi- 110 027 Act. 39 ITA No. ACIT, Central Bal Gopal CIT(A), Delhi’s-31’s order 6150/Del/202 Circle-25, Importers & dated 07.07.2025 involving 5 ; Assessment New Delhi Exporters Private proceedings under Section Year: 2018-19 Limited 153C r.w.s. 143(3) of the WZ-106/141, Act. Rajouri Garden Extension, New Delhi- 110 027
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Heard the assessee as well as the department through their respective learned representatives. Case files perused.
It transpires during the course of hearing that all the instant thirty nine cases have emanated from the learned departmental authorities from search action dated 06.02.2019 carried out in M/s Avtar Singh Kochar & Shri Sudhir Singh Gulati group of cases. And that the learned Assessing Officer of the said searched party(ies) appears to have recorded his former round of section 153C satisfaction in these three assessees’ cases and the seized material therein stood forwarded to their jurisdictional Assessing Officer(s); who, in turn, arrived at his latter round of satisfaction under the very provision followed by issuance of the corresponding notices finally culminating in the impugned assessments forming subject matter of the tribunal’s apt adjudication herein.
It is at this stage that we are informed that the learned CIT(A) records a categoric finding of fact for the “unabated” years that the addition(s) made herein are not based on any specific seized material going by PCIT vs Abhisar Buildwell Pvt. Ltd. (2023) 454 ITR 212 (SC). Learned counsel takes us to the CIT(A) impugned identical/common lower appellate order (in the first assessee’s case) to the very effect; reading as under:
“52. Upon careful consideration of the entire gamut of facts and circumstances of the case and
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the case laws cited above, I am of the considered view that the AO is not justified in making the additions in the assessment orders passed u/s 153C r.w.s 153A of the Act for AYs 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 and 2017-18 as the same are not in accordance with the material found in a search on searched person and the material which has been basis of such additions has neither been noticed, examined nor considered in the satisfaction note recorded by him. Therefore, I find that the said additions are not sustainable in law and as such are liable to be deleted. I hold accordingly. Hence, all the additions made by the AO in the assessment orders so passed for AYs 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 and 2017-18 are hereby deleted.
In view of the foregoing discussion, in conclusion, the appeals for AYs 2011-12, 2012- 13, 2013-14, 2014-15, 2015-16, 2016-17 and 2017-18 are partly allowed. Apart from the issues raised and discussed above, the appellant has raised various other substantive issues of the addition on legal as well as merits and made detailed submissions with documents, which are summarized as under:
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- Non-disposal of objection filed by appellant challenging the satisfaction recorded u/s 153C by the AO; - No separate satisfaction was recorded for each of the AYs; - Approval granted u/s 153D is in mechanical & routine manner; - Statements and commission report relied in the assessment order has no evidentiary effect as the said statements were never confronted with the appellant during assessment and cross examine opportunity was not provided; - Non-compliance of the Indian Evidence Act with regard to reliance on the images retrieved from the digital devices; - lack of enquiry by the AO or relating to absence of basis of additions, etc. - Documents relied in assessment order has no relation with the appellant: - additions of cash purchases on assumptions and estimation, without any basis and single iota of evidence;
- assumptions of payment of commission based on GST rate for all the AYs ignoring the fact that GST came into existence w.e.f. 01.07.2017; - when sales are not disputed, purchases cannot be disallowed that too without rejecting books of 9 | P a g e
accounts and no defects pointed in the books of accounts, etc. - purchases and export sales genuineness substantiated by various documents filed during assessment proceedings and not considered while passing of assessment order; - allegation of over invoicing of export bills whereas various shipments of the assessee were fully examined by the Custom Authorities and examination report duly submitted during assessment; - additions of incentives and duty drawback whereas the same has already recorded in Statement of Profit & Loss. Since the additions are held to be not sustainable in law and have been deleted for all the AYs, the above issues raised on legal as well as merits are not being adjudicated upon here in this order being of academic interest only. 54. In the result, all the appeals for AYs 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 and 2017-18 are partly allowed.”
It is in this identical factual backdrop that the assessees as well as the department have come in their respective appeals or cross-objections; as the case may be, before the tribunal.
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Learned CIT(DR) vehemently submits that the Assessing Officer’s various assessments framed in all these cases had duly discussed the relevant incriminating material. We find no merit in the Revenue’s case herein in all these “unabated” assessment years since the learned CIT(A) has settled the issue that this is a clearcut instance of lack of any incriminating material forming the very basis for making the impugned additions in these three assessee’s hands; whatsoever.
Learned counsel at this stage further seeks to buttress the point that the relevant assessments herein framed in all these three assessee’s cases happen to be u/s 153C of the Act. He takes us to pages 313 to 318 in case of M/s Anmol Traders Pvt. Ltd. that the Assessing Officer of the searched person had recorded his former round of section 153C satisfaction on 19.02.2021 that the corresponding seized material in fact “belongs to” the assessee in assessment years 2013-14 to 2019-20. That being the case, the Revenue could hardly dispute that section 153C(1) read with clauses “a to b” thereto stipulates as to what could he held as belonging to a third party i.e., “any money, bullion, jewellery or other valuable articles or things, seized or requisitioned” ; or “any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to.”, as the case may be. Meaning thereby that these twin categories of the satisfied material could not be held as interchangeable since the legislature has not incorporated the clinching statutory expression “and/or” but used “or” only. We thus invoke stricter interpretation in light of Commissioner of Customs v. Dilip Kumar (2018) 9 SCC 11 | P a g e
1 (FB)(SC) to hold that the impugned section identical 153C satisfactions had not been properly recorded in facts of the instant cases herein.
There is one more equally important legal aspect of the matter which could not be covered at the assessees’ cost. Learned counsel takes us to the assessee’s jurisdictional Assessing Officer’s section 153C latter satisfaction wherein he had not made it clear that the relevant seized material had “a bearing” on determination of the total income as well. The Revenue on the other hand, pleads that such a mistake could not be held as fatal to validity of the impugned assessment as we ought to appreciate the entire facts in totality than adopting a hyper-technical approach. We are of the considered view that the Revenue’s stand hardly carries any merit once hon’ble jurisdictional high court in Saksham Commodities Ltd. Vs. ITO (2024) 464 ITR 1 (Delhi)(HC) has settled the same in the assessee’s favour that the Assessing Officer’s section 153C satisfaction must explicitly state that the seized material carries “a bearing” on determination of the total income of the third party concerned. We thus conclude in this factual backdrop that all these section 153C assessments based on the learned Assessing Officer’s improper satisfaction(s) are not sustainable in law even in both “abated” as well as “unabated” set of assessment years. The same stand quashed in very terms therefore.
All other remaining pleadings between the parties on merits as well as in law; as the case may be, stand rendered academic. 12 | P a g e
In the result, the assessees’ appeals and cross-objections as tabulated below are allowed in above terms. Sl. Assessee Appeal No. Assessment Year Result No. 1. Allowed C.O. No.205/Del/2026 Assessment Year: 2011- 12 2. C.O No.206/Del/2026 Assessment Year: 2012- Allowed 13 3. C.O. No.207/Del/2026 Assessment Year: 2013- Allowed 14 4. C.O. No.208/Del/2026 Assessment Year: 2014- Allowed 15 5. C.O. No.209/Del/2026 Assessment Year: 2015- Allowed 16 C.O. No.210/Del/2026 Assessment Year: 2016- 6. Allowed 17 7. C.O. No.211/Del/2026 Assessment Year: 2017- Allowed 18 8. ITA No. 6149/Del/2025 Assessment Year: 2015- Allowed 16 9 C.O. No.212/Del/2026 Assessment Year: Allowed 2011-12 10 C.O. No.213/Del/2026 Assessment Year: Allowed 2012-13 11 C.O. No.214/Del/2026 Assessment Year: Allowed 2013-14 12 C.O. No.215/Del/2026 Assessment Year: Allowed 2014-15 13 C.O. No.216/Del/2026 Assessment Year: Allowed 2015-16 14 C.O. No.217/Del/2026 Assessment Year: Allowed 2016-17 15 C.O. No.218/Del/2026 Assessment Year: Allowed 2017-18 16 ITA No. 6150/Del/2025 Assessment Year: Allowed 2018-19
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The department’s appeals as tabulated below are dismissed in above terms. Sl. No. Revenue Appeal No Assessment Year Result 1 ITA No.5378/Del/2025 Assessment Year: Dismissed 2011-12 2 ITA No.5379/Del/2025 Assessment Year: Dismissed 2012-13 3 ITA No.5380/Del/2025 Assessment Year: Dismissed 2013-14 4 ITA No.5381/Del/2025 Assessment Year: Dismissed 2014-15 5 ITA No.5382/Del/2025 along Assessment Year: Dismissed 2015-16 6 ITA No.5383/Del/2025 Assessment Year: Dismissed 2016-17 7 ITA No.5384/Del/2025 Assessment Year: Dismissed 2017-18 8 ITA No. 6927/Del/2025 Assessment Year: Dismissed 2018-19 9. Dismissed ITA No. 8051/Del/2025 Assessment Year: 2013-14 10. ITA No. 8052/Del/2025 Assessment Year: Dismissed 2014-15 11 ITA No. 8053/Del/2025 Assessment Year: Dismissed 2015-16 12. ITA No. 8054/Del/2025 Assessment Year: Dismissed 2016-17 13. ITA No. 8055/Del/2025 Assessment Year: Dismissed 2017-18 14. ITA No. 8056/Del/2025 Assessment Year: Dismissed 2018-19 15 ITA No. 8057/Del/2025 Assessment Year: Dismissed 2019-20 16 ITA No.5385/Del/2025 Assessment Year: Dismissed 2011-12 17 ITA No.5386/Del/2025 Assessment Year: Dismissed 2012-13 18 ITA No.5387/Del/2025 Assessment Year: Dismissed 2013-14 19 ITA No.5388/Del/2025 Assessment Year: Dismissed 2014-15
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20 ITA No.5389/Del/2025 Assessment Year: Dismissed 2015-16 21 ITA No.5390/Del/2025 Assessment Year: Dismissed 2016-17 22 ITA No.5391/Del/2025 Assessment Year: Dismissed 2017-18 23 ITA No. 6981/Del/2025 Assessment Year: Dismissed 2018-19
A copy of this common order be placed in all the respective case files.
Order pronounced in the open court on 16.07.2026.
Sd/- Sd/- (M. BALAGANESH) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 16.07.2026 Pooja Mittal, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi
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