In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 4845/Del/2016 : Asstt. Year: 2012-13 Ita No. 4846/Del/2016 : Asstt. Year: 2013-14 Rishi Bansal, Vs Dcit, 132, Doon Palm City, Central Circle, Pathri Bagh, Dehradun Dehradun (Appellant) (Respondent) Pan No. Akvpb7754R Assessee By : Sh. Vivek Aggarwal, Ca Revenue By : Sh. N. S. Jangpangi, Cit Dr Date Of Hearing: 26.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: These Appeals Have Been Filed By The Assessee Against The Orders Of The Ld. Cit(A)-2, Dehradun Dated 31.03.2016. 2. In Ita No. 4845/Del/2016, Following Grounds Have Been Raised By The Assessee: “1. That The Impugned Proceeding Initiated U/S 153A & Passing The Impugned Order Under That Section Is Bad In Law & Without Jurisdiction & Addition Are Also Made Without Any Incriminating Material Found During The Course Of Search. 2. That Having Regard To The Fact & Circumstances Of The Case, Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Action Of Ao In Making Addition Of Rs.50 Lacs Which Was Made By The Ao Only On The Basis Of Alleged Statement Which Has Even Being Retracted On 09.07.2012 By The Assessee. Thus The Addition Is Not Sustainable. 3. That In Any Case & In Any View Of The Matter Action Of Ld. Cit(A) In Making Addition Of Rs.50 Lacs Is Bad In Law & Against The Facts & Circumstances Of The Case.“

house property and other sources. A search u/s 132 of the Income Tax Act, 1961 took place in the business and residential premises of the assessee on 26.04.2012 in M/s Ganga Realtors Group of cases. The assessee filed return of income on 10.07.2014 declaring income of Rs.4,72,526/-and the assessment u/s 153A was completed on 01.09.2014. Surrendered amount