Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 405/Pat/2024 Assessment Year: 2016-2017 Pioneer Education Society,……….…….....……Appellant C-310/311, Unitech Business Zone Nirvana Country, South City-Ii, Sector-50, Haryana, Pin Code No.122018 [Pan:Aadap0174C] -Vs.- Income Tax Officer,……………………………….Respondent Ward-1(1), Patna, Lok Nayak Jai Prakash Bhawan, New Dak Bunglow, Patna-800001, Bihar Appearances By: Shri Yatin Sharma, Advocate, Appeared On Behalf Of The Assessee Rinku Singh, Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 21, 2025 Date Of Pronouncing The Order: April 24, 2025 O R D E R

section 68 of the Act and added to the total income of the assessee. Therefore, the total addition comes to Rs.4,07,90,320/- (Rs.10,55,000/- plus Rs.3,97,35,320/-). 2.1. In support of rent debited in the income & expenditure account to the tune of Rs.3,43,84,722/-, the assessee furnished copy of three Memorandum of Understandings