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31 results for “condonation of delay”+ Set Off of Lossesclear

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Mumbai476Chennai467Kolkata291Delhi244Hyderabad210Ahmedabad206Jaipur164Pune154Chandigarh147Bangalore126Raipur75Lucknow74Indore60Surat55Rajkot49Cuttack48Nagpur46Cochin43Visakhapatnam41Patna31SC24Jodhpur24Amritsar22Guwahati15Panaji10Agra8Allahabad8Varanasi7Dehradun4Ranchi3Jabalpur3A.K. SIKRI ROHINTON FALI NARIMAN1

Key Topics

Limitation/Time-bar20Condonation of Delay20Section 26314Addition to Income14Section 14413Section 25012Section 1489Section 143(2)9Section 44A

BAIJU ROY,PATNA vs. ITO, WARD-4(2), PATNA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 13/PAT/2022[2016-17]Status: DisposedITAT Patna02 Jun 2023AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 10(37)Section 133(6)Section 2(14)(iii)Section 45(5)Section 54BSection 54F

loss”. 9. We do not deem it necessary to re-cite or recapitulate the proposition laid down in other decisions. It is suffice to say that the Honble Courts are unanimous in their approach to propound that whenever the reasons 8 Assessment Year: 2016-2017 Baiju Roy assigned by an applicant for explaining the condonation of delay, then such reasons

Showing 1–20 of 31 · Page 1 of 2

9
Section 1478
Section 58
Natural Justice7

MOHAMMAD SOHEL ALAM,PURNEA vs. ITO, WARD 3 (1), PURNEA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 340/PAT/2023[2017-18]Status: DisposedITAT Patna12 Sept 2024AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 249Section 253Section 3Section 5

loss”. 5. We do not deem it necessary to re-cite or recapitulate the proposition laid down in other decisions. It is suffice to say that the Honble Courts are unanimous in their approach to propound that whenever the reasons assigned by an applicant for explaining the condonation of delay, then such reasons are to be construed with a justice

LAL BAHADUR PANDEY,SARAN vs. ITO, WARD,-2(2), CHHAPARA

In the result, the Stay Application of the assessee is dismissed and the appeal of the assessee is allowed for statistical purposes

ITA 507/PAT/2024[2017-18]Status: DisposedITAT Patna22 Aug 2024AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borads.A. No. 9/Pat/2024 (In Ita No. 507/Pat/2024) Assessment Year: 2017-2018 Lal Bahadur Pandey,…………………………..Applicant Vill. Bheldi, Chapra, Dist. Saran, Bihar-841402 [Pan:Bifpp6882H] -Vs.- Income Tax Officer,…………………………….Respondent Ward-2(2), Chapra, Dist. Saran, Bihar & I.T.A. No. 507/Pat/2024 Assessment Year: 2017-2018 Lal Bahadur Pandey,…………………………..Appellant Vill. Bheldi, Chapra, Dist. Saran, Bihar-841402 [Pan:Bifpp6882H] -Vs.- Income Tax Officer,…………………………….Respondent Ward-2(2), Chapra, Dist. Saran, Bihar Appearances By: Shri Narendra Kumar, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kumar, Sr. D.R., Appeared On Behalf Of The Revenue

Section 249Section 253Section 3Section 5

loss”. S.A. No. 9/PAT/2024 (A.Y. 2017-2018) (in ITA No. 507/PAT/2024) & Assessment year: 2017-2018 Lal Bahadur Pandey 7. We do not deem it necessary to re-cite or recapitulate the proposition laid down in other decisions. It is suffice to say that the Honble Courts are unanimous in their approach to propound that whenever the reasons assigned

M/S GEETANJALI ESTATE PVT LTD,PATNA vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is dismissed

ITA 20/PAT/2019[2013-14]Status: DisposedITAT Patna05 Jul 2024AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 249Section 253Section 3Section 5

loss”. 7. We do not deem it necessary to re-cite or recapitulate the proposition laid down in other decisions. It is suffice to say that the Honble Courts are unanimous in their approach to propound that whenever the reasons assigned by an applicant for explaining the condonation of delay, then such reasons are to be construed with a justice

PAPPU KUMAR,PATNA vs. ITO, WARD- 5 (4), PATNA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 322/PAT/2023[2014-15]Status: DisposedITAT Patna25 Sept 2024AY 2014-15

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 249Section 253Section 3Section 5

loss”. 5. We do not deem it necessary to re-cite or recapitulate the proposition laid down in other decisions. It is suffice to say that the Honble Courts are unanimous in their approach to propound that whenever the reasons assigned by an applicant for explaining the condonation of delay, then such reasons are to be construed with a justice

PATNA SMART CITY LIMITED,PATNA vs. INCOME TAX OFFICER, PTN-W-(21)(91), PATNA

In the result, the appeal of the appellant is dismissed

ITA 314/PAT/2025[2022-23]Status: DisposedITAT Patna18 Nov 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 2(45)Section 234BSection 250

set up by the State Government of Bihar with an object to build a Smart city in accordance with the "Prime Minister's Smart City Program". The appellant is fully funded by the Central Government and also the State Government of Bihar. The objects of the appellant are well elucidated in the Memorandum of Association, the same inter-alia

NORTH BIHAR CONSTRUCTION PRIVATE LIMITED,PATNA vs. DCIT CIRCLE-3, DARBHANGA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 243/PAT/2023[2014-15]Status: DisposedITAT Patna10 Dec 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 243/Pat/2023 Assessment Year: 2014-2015 North Bihar Construction Pvt. Limited,………Appellant Singh Sadan, Veer Kunwar Singh Path, Danapur Cantt., Patna-801503, Bihar [Pan:Aabcn9870B] -Vs.- Deputy Commissioner Of Income Tax,.…...Respondent Circle-3, Darbhanga Darbhanga-846001, Bihar Appearances By: Shri Pankaj Jyoti, C.A., Appeared On Behalf Of The Assessee Shri Ajay Kr. Shukla, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 13, 2024 Date Of Pronouncing The Order: December 10, 2024 O R D E R

Section 143(2)Section 144

delay is condoned. 4. Brief facts of the case are that the assessee is a Private Limited Company, which is engaged in the business of construction. The assessee filed its return of income for the assessment year 2014-15 declaring total income at Rs.27,46,090/-. The case of the assessee was selected for scrutiny for the reason that there

SANJAY KUMAR,UJJAIN vs. DC/AC, CIRCLE-1, PATNA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 696/PAT/2024[2011-12]Status: HeardITAT Patna20 Mar 2025AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 696/Pat/2024 Assessment Year: 2011-2012 Sanjay Kumar,………………………….……..……Appellant B-20/19, Ved Nagar, Indore Road, Nanakheda, Ujjain, Madhya Pradesh-456010, India [Pan:Amgpk0372B] -Vs.- Deputy Commissioner /Assistant Commissioner Of Income Tax,…..…………….………...……...Respondent Circle-1, Patna Appearances By: Shri Ashish Kr. Agrawal, C.A., Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: March 10, 2025 Date Of Pronouncing The Order: March 20, 2025 O R D E R

Section 142(1)Section 148

delay is condoned. 4. Brief facts of the case are that the assessee is an individual, who filed his return of income for the assessment year 2011-12 showing total income of Rs.18,63,160/-. The case was reopened to examine the fresh unsecured loan amounting to Rs.24,60,328/- introduced during the A.Y. 2011-12. The required approval

RUBAN PATLIPUTRA HOSPITAL PRIVATE LIMITED,PATNA vs. CIT, PATNA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 653/PAT/2024[2014-15]Status: DisposedITAT Patna26 May 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 653/Pat/2024 Assessment Year: 2014-2015 Ruban Patliputra Hospital Private Limited,……………………………………….………Appellant 19, Patliputra Colony, Patna-800013, Bihar [Pan:Aafcr2222R] -Vs.- Nfac,…………………………………………….…...Respondent New Delhi, Appearances By: Shri A.K. Rastogi, Sr. Advocate, Appeared On Behalf Of The Assessee Sm. Rinku Singh, Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 16, 2025 Date Of Pronouncing The Order: May 26, 2025 O R D E R

Section 143(2)Section 148Section 271(1)(c)Section 35A

delay is condoned. 4. Brief facts of the case are that the assessee is a Private Limited Company engaged in running Nursing Homes and Emergency Services and sale of medicine. The assessee filed its return of income electronically on 29.11.2014 declaring NIL income claiming loss at Rs.34,64,44,303/-. The return of income was revised by the assessee

MANOJ KUMAR DAS,BEGUSARAI vs. ASSESSMENT UNIT INCOME TAX DEPARTMENT, DELHI

Appeal is allowed for statistical purposes

ITA 391/PAT/2025[2015-16]Status: DisposedITAT Patna30 Oct 2025AY 2015-16

Bench: 19/07/2025. The Appeal Is Delayed By Around 37 Days. 4. That The Assessee States That The Reason For Delay Is That The Assessee Is Suffering From Hiv Aids & Is Constantly Under Treatment. Copy Of Medical Treatment Is Enclosed.

Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 68

loss and injury. It is, therefore, prayed that this Hon'ble Tribunal may graciously be pleased to consider the submissions as made in the foregoing paragraphs and further be pleased to condone delay, if any, in the filing of the instant appeal.” 1.1 Considering the reasons given in the said petition, the delay is hereby condoned and the appeal

PROTECH PACKAGING PVT. LTD,PATNA vs. ITO, WARD, 2(2), PATNA, PATNA

In the result, appeal of the assessee stands partly allowed for

ITA 214/PAT/2025[2015-16]Status: DisposedITAT Patna30 Sept 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy(Kz) Assessment Year : 2015-16 Protech Packaging Pvt Ltd., 3A, Vs. Ito, Ward 2(2), Patna Ground Floor, Pushpanjali Venkatesh, Budh Marg, Patna- 80000 Pan/Gir No. Aagcp 1473 K (Appellant) .. ( Respondent) Assessee By : None Revenue By : Shri Ashwani Kumar Singhal, Jcit Date Of Hearing : 28/08/2025 Date Of Pronouncement : 30/09/2025 O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nafc), New Delhi Nfac), Delhi Dated 23.06.2023 In Appeal No.Cit(A), Patna -1/10147/2017-18 Passed For Assessment Year 2015-16. 2. The Appeal Is Time Barred By 607 Days. The Assessee Has Filed Condonation Petition Stating That The Order Of Ld Cit(A) Was Passed On 23.6.2023 & The Appeal Was Required To Be Filed Within 60 Days, However, Due To Serious Illness Of The Accountant Who Was Entrusted To Take Steps In P A G E 1 | 5 Assessment Year : 2015-16

For Appellant: NoneFor Respondent: Shri Ashwani Kumar Singhal, JCIT
Section 143(2)Section 56

loss of revenue. In these circumstances, it is prayed to condone the delay. Ld Sr DR opposed the condonation petition and stated that no reasonable cause has been shown by the assessee to condone the delay. 3. After considering the condonation petition, I am satisfied that there was reasonable cause in not filing the appeal within the prescribed time. Even

RANI DEVI,PATNA vs. INCOME TAX OFFICER, PATNA

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 308/PAT/2025[2017-18]Status: DisposedITAT Patna25 Nov 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 145(3)Section 250Section 44ASection 69ASection 80C

delay is condoned and the appeal is admitted for hearing. 5. Brief facts of the case are that the assessee is an individual, who is running a wholesale business as her proprietorship concern in the name of M/s. Gwalior Industries. The assessee filed her return of income electronically showing aggregate income of Rs.6,48,570/-. The case was selected

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S UTTAR BIHAR GRAMIN BANK, MUZAFFARPUR

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 30/PAT/2021[2014-15]Status: DisposedITAT Patna25 Feb 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 250Section 36(1)(viia)Section 36(1)(vila)

delay is condoned and the appeal is admitted for adjudication. 2. The Revenue is in appeal before the Tribunal raising the following grounds of appeal: “i) On the facts and in the circumstances of the case, the Ld. CIT(A) erred in law by deleting the disallowance of Rs. 43,67,25,641/- made

ASHUTOSH KUMAR PRABHAT,ARRAH vs. PCIT-1, PATNA

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 564/PAT/2024[2018-19]Status: DisposedITAT Patna06 May 2025AY 2018-19

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 147Section 154Section 263

condone the delay and admit the appeal for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the grounds of appeal hereto are without prejudice to each other. 2. For that the order of the Id. Principal Commissioner of Income Tax-1, Patna, is bad both

PRERNA AGENCY PVT LTD,KOLKATA vs. INCOME TAX OFFICER, WARD 2(1), PATNA

In the result, the appeal filed by the assessee is allowed

ITA 285/PAT/2023[2013-2014]Status: DisposedITAT Patna26 Mar 2025AY 2013-2014

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 143(3)Section 147Section 148Section 151

delay is hereby condoned. 4. Brief facts of the case of the assessee are that the assessee M/s Prerna Agency pvt. Ltd. derived income from share trading, filed its return of income for AY 2013-14, and assessment u/s 143(3) of the Act was completed on 29.02.2016. Subsequently on an information received from investigation wing that M/s Prerna Agency

SRIRAM ENTERPRISES,PATNA vs. PCIT (CENTRAL), PATNA

In the result, the appeal of the assessee is allowed

ITA 76/PAT/2023[2018-19]Status: DisposedITAT Patna08 May 2024AY 2018-19

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No. 76/Pat/2023 Assessment Year: 2018-2019 Sriram Enterprises,………………………..........Appellant C/O. Nirmal & Associates, Nepali Kothi, Opposite Gasoline Petrol Pump, Boring Road, Patna-800001 [Pan:Aarfs8853J] -Vs.- Principal Commissioner Of Income Tax (Central), Patna,…………………………………..……………..Respondent, Bihar-800001 Appearances By: Shri Nishant Maitin, C.A., Appeared On Behalf Of The Assessee Md. A.H. Chowdhary, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : 5Th March, 2024 Date Of Pronouncing The Order: May 8Th, 2024 O R D E R

Section 133ASection 142(1)Section 143(1)Section 263

set aside. 3. The Registry has pointed out that the appeal is time barred by 313 days. In order to explain the delay, the assessee has annexed an application alongwith the appeal for condonation of delay. 3.1. Shri Roshan Kumar Agrawal, Partner of the assessee- Company has filed application for condonation of delay, wherein it has been pleaded that Shri

SHARDINDU PRASAD SINGH,PATNA vs. ITO, WARD-6(4), PATNA

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 630/PAT/2024[2016-17]Status: DisposedITAT Patna15 Oct 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 250Section 271(1)(c)

loss arises without a transaction in between the receiver & payer by making entries in the books of account of the receiver for the amount received or receivable and payer making entry in its books of account for any paid or payable. Also no profit/gain can accrue or arises only on entering into an agreement for doing certain project on exchange

RANJAY KUMAR DIWAKAR,NAWADA vs. ITO, WARD-2(5), BIHAR SHARIF, BIHAR SHARIF

The appeal of the assessee is allowed for statistical purposes

ITA 227/PAT/2024[2017-18]Status: DisposedITAT Patna07 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.227/Pat/2024 Assessment Year: 2017-18 Ranjay Kumar Diwakar.………………………………………..………….……Appellant M/S Nidhi Pharma, Purani Jail Road, Nawada, Bihar-805110. [Pan: Aoppd7881R] Vs. Ito, Ward-2(5), Bihar Sharif.……....….….. ……………….........……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 Date Of Pronouncing The Order : February 07, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 12.09.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 79 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause & The Delay Was Not Intentional. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Case Are That In The Case Of The Assessee, Notice U/S 142(1) Of The Act Was Issued For Calling The Assessee To Submit True & Correct Return Of Income In Respect Of Assessment Year 2017-18 And

Section 142(1)Section 144Section 250

condone the delay in filing the appeal and adjudicate the appeal on merits of the case. 3. Brief facts of the case are that in the case of the assessee, notice u/s 142(1) of the Act was issued for calling the assessee to submit true and correct return of income in respect of assessment year 2017-18 and I.T.A

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

ITA 176/PAT/2023[2016-17]Status: DisposedITAT Patna13 May 2024AY 2016-17

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2

For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263

condone the delay and admit the appeals for hearing on merits. 3. As the issues raised in the present appeals are identical, they were heard together and are being disposed off by way of this common order. For the sake of convenience, we first take up the assessee’s appeal for Assessment Year 2015-16 and our decisions therein shall

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

ITA 177/PAT/2023[2017-18]Status: DisposedITAT Patna13 May 2024AY 2017-18

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2

For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263

condone the delay and admit the appeals for hearing on merits. 3. As the issues raised in the present appeals are identical, they were heard together and are being disposed off by way of this common order. For the sake of convenience, we first take up the assessee’s appeal for Assessment Year 2015-16 and our decisions therein shall