Loading judgment…
No AI summary yet for this case.
Income Tax Appellate Tribunal, “E” BENCH, MUMBAI
Before: SHRI BR BASKARAN, AM & SHRI ABY T. VARKEY, JM
Per Bench: All these appeals preferred by the revenue are against the common orders passed by the Learned Commissioner Income Tax (Appeals)-48 [herein after referred to as Ld. CIT(A)], Mumbai for A.Y 2016-17, 2017-18 & 2018-19 dated 01.03.2023 and the Ld. CIT(A) common order dated 21.03.2023 for AYs 2019-20, 2020-21 & 2021-22.Since issues involved are common, all the appeals for all the assessment year/years (hereinafter referred to as “AY”) were heard together. Both the parties also argued them together raising similar arguments on these issues. Accordingly, for the sake of convenience and brevity, we dispose all the appeals by this consolidated order.
Before we advert to the grounds taken in the appeals, it would first be relevant to cull out the basic facts of the case. Search u/s 132 of the Income Tax Act, 1961 (hereinafter referred to as “the “Act”) was conducted against the JMG Group and others, on 08-02-2021 thereby triggering section 153A of the Act. Prior to the date of search, the income-tax assessment under section (hereinafter referred to as “u/s.