RADHA MADHAV ECO-INDUSTRIAL PARK,VALSAD vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VAPI

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

ACIT, CENTRAL CIRCLE, VAPI vs. RADHA MADHAV ECO INDUSTRIAL PARK, VAPI

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

RADHA MADHAV ECO-INDUSTRIAL PARK,VAPI vs. ACIT, CENTARL CIRCLE-1, VAPI, VAPI

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

M/S. PATEL AMBALAL HARGOVANDAS & CO.,,SURAT vs. THE DCIT, CENTRAL CIRCLE-2,, SURAT

In the results, appeal filed by Revenue (in IT(SS)A Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं/.It(Ss)A No.49/Srt/2022 Assessment Year: (2019-20) (Physical Hearing) The Acit, Central Circle-2, Vs. Rasikbhai Narottamdas Patel, Surat. Flat No.9-10, Mahavir Nagar Co.Op H.S. Ltd., Bldg-12, Nr. Gayatri Mandir, Udhna Magdalla Road, Surat – 395007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Adgpp4550M (Appellant) (Respondent) आयकर अपील सं/.It(Ss)A No.86/Srt/2022 Assessment Year: (2015-16) The Dcit, Central Circle-2, Vs. Ashish Karamshibhai Koshiya, Surat. 40, Jivandeep Soceity, Singanpor Road, Katargam, Surat, Gujarat – 395004. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aojpk1118G (Appellant) (Respondent) आयकर अपील सं/.Ita No.185/Srt/2022 Assessment Year: (2020-21) M/S. Patel Ambalal Hargovandas Vs. The Dcit, Central Circle-2 & Co., Surat. 5/725, Haripura, Bhavaniwad, Opp. Dhobi Sheri, Surat – 395003. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aadfp2517N (Appellant) (Respondent) Appellant By Shri Ashok B. Koli, Cit(Dr) Shri Vartik Choksi, Shri Biren Shah & Shri Respondent By Nitin Gheewala, Ar Date Of Hearing 26/04/2023 Date Of Pronouncement 26/05/2023 आदेश /O R D E R Per Bench:

Section 292C(1) of the Act. [ii] On the facts and in the circumstances of the case and in law, the Ld.CIT(A) has erred in deleting the protective addition made by the Assessing Officer of Rs.10,74,15,724/- on account of unaccounted income under Sec.69A of the Act by observing that the Assessing Officer was not able

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT vs. SHRI JIGNESH MAHESH AMIN, SURAT

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) A.C.I.T., Shri Jignesh Mahesh Amin, Central Circle-3, 418, Royal Trading Tower, Nr. Vs. Surat. Ratan Cinema, Salabatpura, Surat-395003. Pan No. Aajpa 2349 H Appellant/ Assessee Respondent/ Revenue

Section 133A was carried out on the project undertaken by assessee. During the course of survey, certain diaries and documents were found from the possession of a real estate broker, who was present at the premises during the course of survey which was later on impounded. On perusal of said diary, it was revealed that the assessee made unaccounted investment

SHRIFAL IMPEX PRIVATE LIMITED,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

section 147 shows that for taking action under thesaid provision what is required is that (i) the ITO has received ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. information, and (ii) in consequence of such information he has reason to believe that income chargeable to tax has escaped assessment for any assessment year. The question was whether

SHRIFAL IMPEX PVT. LTD.,,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

section 147 shows that for taking action under thesaid provision what is required is that (i) the ITO has received ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. information, and (ii) in consequence of such information he has reason to believe that income chargeable to tax has escaped assessment for any assessment year. The question was whether

SHRIFAL IMPEX PVT. LTD.,,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

section 147 shows that for taking action under thesaid provision what is required is that (i) the ITO has received ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. information, and (ii) in consequence of such information he has reason to believe that income chargeable to tax has escaped assessment for any assessment year. The question was whether

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT vs. SHRINIDHI ENTERPRIZE, SURAT

In the result, both the appeals of the Revenue are, hereby, dismissed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita Nos.914/Srt/2024 & 797/Srt/2024 िनधा"रण वष" /Assessment Years : 2015-16 & 2016-17 The Acit Shrinidhi Enterprize Central Circle-3 बनाम/ 6/1862, 63, Ground Floor Surat Ghanshyam Bhuvan V/S. Bali Sheri, Mahidharpura Surat – 395 003 "थायी लेखा सं./Pan:Acbfs 6484 R (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rasesh Shah, Ca Revenue By : Shri Ravi Kant Gupta, Cit(Dr) Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/08/2025 घोषणा की तारीख /Date Of Pronouncement: 23/09/2025 आदेश/O R D E R Per Sanjay Garg:

Sections 132 and 133A of the Act were carried out involving the group known as Sadhani Brothers. This group was found to be involved in providing accommodation entries by managing financial affairs of about 873 persons/entities, which included parties with whom the assessee had transactions for labour work contracts. 3. During the reassessment

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT, SURAT vs. SHRINIDHI ENTERPRIZE , SURAT

In the result, both the appeals of the Revenue are, hereby, dismissed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita Nos.914/Srt/2024 & 797/Srt/2024 िनधा"रण वष" /Assessment Years : 2015-16 & 2016-17 The Acit Shrinidhi Enterprize Central Circle-3 बनाम/ 6/1862, 63, Ground Floor Surat Ghanshyam Bhuvan V/S. Bali Sheri, Mahidharpura Surat – 395 003 "थायी लेखा सं./Pan:Acbfs 6484 R (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rasesh Shah, Ca Revenue By : Shri Ravi Kant Gupta, Cit(Dr) Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/08/2025 घोषणा की तारीख /Date Of Pronouncement: 23/09/2025 आदेश/O R D E R Per Sanjay Garg:

Sections 132 and 133A of the Act were carried out involving the group known as Sadhani Brothers. This group was found to be involved in providing accommodation entries by managing financial affairs of about 873 persons/entities, which included parties with whom the assessee had transactions for labour work contracts. 3. During the reassessment

AJAY KALISHCHANDRA BOHRA,DAMAN vs. PCIT, VALSAD

In the result, the grounds of appeal raised by the assessee are allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 549/Srt/2024 (Ay 2017-18) (Physical Court Hearing) Ajay Kalishchandra Bohra Principal Commissioner Of Income- 1, Plot No.22B, Daman Industrial Tax, Valsad, 301, 3Rd Floor, Palak बनाम Estate, Somnath Road, Dabhel, Arcade, Shantinagar, Tithal Road, Vs Daman-396 215 Valsad-396 001 [Pan : Ackpb 2567 R] अपीलाथ"/Appellant ""थ" /Respondent

reassessment order was passed in both the assessment years. However, show cause notice issued under section 263 was issued only in respect of assessment year 2017-18 only and that similar re-assessment proceedings for assessment year 2016-17 was not revised. The assessee in response to show cause notice field detailed reply. The reply of assessee is duly scanned

NAZAR IMPEX PRIVATE LIMITED,SURAT vs. INCOME TAX OFFICER-1(1)(3), SURAT (CURRENT JURISDICTION), SURAT

In the result, assessee’s appeal is allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1212/Srt/2024 Assessment Year: (2012-13) (Hybrid Hearing) Nazar Impex Pvt.Ltd. Income Tax Officer बनाम/ 408, Saryu Diamond Complex, Ward-1(1)(3), Surat, Aaykar Vs. Jadda Khadi, Mahidharpura, Bhavan, Majura Gate, Opp. New Surat-395 003 Civil Hospital, Surat-395 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccn3603R (अपीलाथ"/Appellant) (प्र"थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Himanshu Gandhi, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 04/06/2025 उद्घोषणा की तारीख/Date Of Pronouncement 21/07/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, ‘The Act’), Dated 26.09.2024 By The National Faceless Appeal Centre, Delhi /Commissioner Of Income-Tax (Appeals), [In Short ‘Nfac/Cit(A)’] For The Assessment Year (Ay) 2012-13, Which In Turn Assessment Order Passed By Assessing Officer (In Short, ‘Ao’) U/S 144 R.W.S. 147 Of The Act On 30.12.2019. 2. Grounds Of Appeal Raised By The Assessee For The Appeals Are As Under: “1. Ground 6. On The Facts & Circumstances Of The Case & Law, The Ld. Cit(A) Erred In Confirming Rejection Of Books Of Account Under Section 145(3) Of Income Tax, Act 1961 Without Pointing Out Any Defect In Books Of Account & Even The Return Income On The Basis Of Books Of Account Were Also Not Disputed.

section 151 of Income Tax Act, 1961. 6. Ground 3. On the facts and circumstances of the case and law, the Ld. CIT(A) failed to considered that the issue which is subject matter of appeal cannot be considered again in reassessment proceeding. 7. Ground 4. On the facts and circumstances of the case

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

133A was conducted in M Poonam group on 21.02.2018 by the investigation wing, Vapi at 3 premises namely M Poonam Developers, M/s Lotus Infra and M Poonam Construction. Accordingly, cases of the appellant were selected for assessment / re-assessment and Ld. Assessing Officer made huge addition in all the years under consideration. Ld. CIT(A) has reduced addition. Both assessee

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

133A was conducted in M Poonam group on 21.02.2018 by the investigation wing, Vapi at 3 premises namely M Poonam Developers, M/s Lotus Infra and M Poonam Construction. Accordingly, cases of the appellant were selected for assessment / re-assessment and Ld. Assessing Officer made huge addition in all the years under consideration. Ld. CIT(A) has reduced addition. Both assessee

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

133A was conducted in M Poonam group on 21.02.2018 by the investigation wing, Vapi at 3 premises namely M Poonam Developers, M/s Lotus Infra and M Poonam Construction. Accordingly, cases of the appellant were selected for assessment / re-assessment and Ld. Assessing Officer made huge addition in all the years under consideration. Ld. CIT(A) has reduced addition. Both assessee

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

133A was conducted in M Poonam group on 21.02.2018 by the investigation wing, Vapi at 3 premises namely M Poonam Developers, M/s Lotus Infra and M Poonam Construction. Accordingly, cases of the appellant were selected for assessment / re-assessment and Ld. Assessing Officer made huge addition in all the years under consideration. Ld. CIT(A) has reduced addition. Both assessee

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

133A was conducted in M Poonam group on 21.02.2018 by the investigation wing, Vapi at 3 premises namely M Poonam Developers, M/s Lotus Infra and M Poonam Construction. Accordingly, cases of the appellant were selected for assessment / re-assessment and Ld. Assessing Officer made huge addition in all the years under consideration. Ld. CIT(A) has reduced addition. Both assessee

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

133A was conducted in M Poonam group on 21.02.2018 by the investigation wing, Vapi at 3 premises namely M Poonam Developers, M/s Lotus Infra and M Poonam Construction. Accordingly, cases of the appellant were selected for assessment / re-assessment and Ld. Assessing Officer made huge addition in all the years under consideration. Ld. CIT(A) has reduced addition. Both assessee