ACIT CENTRAL CIRCLE 1(3) AHMEDABAD, AHMEDABAD V. BIPIN AMARCHAND GALA L/H LATE SHRI AMARCHAND RAMJI GALA, AHMEDABAD

ITSSA 17/AHD/2025

AI Insights

The case involves appeals by the Revenue against the decision of the Commissioner of Income Tax (Appeals) which quashed the assessment orders for the assessment years 2014-15 and 2015-16. The assessments were made under Section 143(3) read with Section 153C of the Income Tax Act, 1961, following a search and seizure operation. The main legal issue was the jurisdiction to initiate proceedings under Section 153C for the specified assessment years. The Tribunal referenced the Supreme Court's decision in Super Malls (P.) Ltd. vs. Pr.CIT and other cases to conclude that the assessments were invalid as they were initiated outside the permissible period.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 712904 (ITAT-AHMEDABAD)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 28-07-2025
• Appeal Filed By: Department
• Order Result: Dismissed
• Assessment Year: 2014-2015
• Other Referred Cases: Super Malls(P.) Ltd. Vs. Pr.CIT, DCIT \/ Suraj Ltd., CIT \/ Jasjit Singh
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SHER SINGH
• Assessee Lawyers: ASEEM THAKKAR
• Keywords: Document seized; Documents seized; Search and seizure; Assessment record
• Section: 143(3); 132; 153A; 69C

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SHRI T.R SENTHIL KUMAR, JUDICIAL MEMBER And SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER IT(SS)A. Nos.17 & 18/Ahd/2025 (Assessment Years: 2014-15 & 2015-16) The Assistant Commissioner of Income Tax, Central Circle 1(3), Ahmedabad. Vs. Bipin Amarchand Gala L/H Late Shri Amarchand Ramji Gala, Navneet House, Gurukul Road, Memnagar, Ahmedabad-380009. [PAN No. AABPG1353K] (Appellant) .. (Respondent) Appellant by : Shri Sher Singh, CIT.DR Respondent by: Shri Aseem Thakkar, AR Date of Hearing 17.07.2025 Date of Pronouncement 28.07.2025 O R D E R PER T.R. SENTHIL KUMAR, JUDICIAL MEMBER These two appeals are filed by the Revenue as against common appellate order dated 31.12.2024 passed by the Commissioner of Income Tax (Appeals-11), Ahmedabad, arising out of the assessment order passed under section 143(3) r.w.s 153C of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] relating to the Asst. Years 2014-15 and 2015-16 respectively. Since the common issue is involved in both appeals, the same are being disposed of by this common order. Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 2– 2. The brief facts of the case are that Assessee is an individual filed his original return of income for the Asst. Year 2014-15 on 27.07.2014 declaring total income of Rs.67,67,000/- and also for the Asst. Year 2015-16 on 28.08.2015 declaring total income of Rs.17,68,020/-. The assessee was a partner in various firms that were carrying on the business of construction and finance. A search and seizure action u/s.132 of the Act was carried out in the case of Land Broker & Financier on 15.10.2019 and also in the case of Shri Suresh R. Thakkar, a land dealer/broker who was involved in land dealings and brokerage jobs. During the course of the search, various incriminating materials and digital data were found and seized from the mobile phone of Shri Suresh R. Thakkar. Few of the incriminating materials and digital data seized from the premises were related /pertained to the assessee. Accordingly, a satisfaction note was recorded on 04.08.2022 in accordance with the provisions of section 153C of the Act by the searched Assessing Officer and the notices u/s.153C were issued to the assessee on 04.08.2022 for the Asst. Year 2014-15 to Asst. Year 2020-21. In response, the assessee filed returns of income on 27.07.2014 as filed in the original returns. The assessment u/s.143(3) r.w.s 153C were completed, making additions u/s.69B and 69C of the Act as follows: Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 3– A.Y Date of order passed u/s.143(3) r.w.s 153C of the Act Amount of addition (In Rs.) Nature of Additions 2014-15 02.06.2023 2,52,05,748/- 2,50,374/- Addition u/s.69B of the Act. Addition u/s.69C of the Act. 2015-16 02.06.2023 1.83,62,198/- 1,81,062/- Addition u/s.69B of the Act. Addition u/s.69C of the Act. 3. Aggrieved against the Assessment Orders the assessee filed appeal before the Ld.CIT(A) and challenged the very basis of assessment framed u/s.153C of the Act for the Asst. Years 2014-15 and 2015-16 were time barred. The Ld.CIT(A) considered the objection filed by the assessee and thereby held that the Assessment Orders passed for the Asst. Years 2014-15 and 2015-16 are beyond the Jurisdiction following the Supreme Court Judgement in the case of Super Malls(P.) Ltd. Vs. Pr.CIT reported in [2020] 273 taxmann 556 and quashed the Assessment Orders by observing as follows: “…6.4.2 In the instant case of the Appellant, the Assessing Officer of the searched person and the other person is the same, therefore, one satisfaction note prepared by the Assessing Officer is sufficient, as he himself is the Assessing Officer of the searched person and also the Assessing Officer of the other person. The second requirement of transmitting the documents so seized from the searched person would not be there as he himself will be the Assessing Officer of the searched person and the other person and therefore there is no question of transmitting such seized documents to himself. To quote from the Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 4– order of the Hon'ble Supreme Court as held in the case of Super Malls (P.) Ltd. vs. Pr. CIT [2020] 273 Taxman 556 (SC): \"In case, where the Assessing Officer of the searched person and the other person is the same, there can be one satisfaction note prepared by the Assessing Officer, as he himself is the Assessing Officer of the searched person and also the Assessing Officer of the other person. However, as observed hereinabove, he must be conscious and satisfied that the documents seized/recovered from the searched person belonged to the other person. In such a situation, the satisfaction note would be qua the other person. The second requirement of transmitting the documents so seized from the searched person would not be there as he himself will be the Assessing Officer of the searched person and the other person and therefore there is no question of transmitting such seized documents to himself. (Emphasis supplied.)\" 6.5 Therefore, in view of the settled legal position, the period of six years would have to be reckoned with respect to the date of recording of satisfaction note, that is on 04.08.2022 and not the date of search as taken by the AO. As discussed hereinabove, in terms of proviso to Section 153C of the Act, a reference to the date of the search under the second proviso to Section 153A of the Act has to be construed as the date of handing over of assets/documents belonging to the assessee (being the person other than the one searched) to the AO having jurisdiction to assess the said assessee. In the instant case, satisfaction note recorded on 04.08.2022. Therefore, the seized documents were deemed transferred to the common AO on the date of recording of satisfaction by the common AO, which falls in the F.Y.2022-23 relevant to A.Y.2023-24. Therefore, as per the proviso to section 153C, the proceedings u/s 153C of the Act could have been validly initiated in the case of the appellant for the six years preceding to the A.Y.2023-24 i.e. for the A.Y.2017-18 to A.Y.2022-23 only. However, as per satisfaction note, dated 04.08.2022, the AO reckoned the preceding six years from A.Y 2014-15 to A.Y.2020-21. In view of the above facts, I am of the considered opinion, that the AO had no jurisdiction to initiate proceedings under Section 153C of the Act for the A.Y.2014-15. As the issue of jurisdiction goes to the root of the matter, considering the entirety of facts and circumstances, it is held that issuance of notice u/s. 153C could not be sustained in the eyes of law for the year under consideration. Resultantly, the consequential assessment order framed by the AO would have Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 5– no legs to stand. Delving into the merits of the case has, therefore, been rendered merely academic in nature. Therefore, the order of the AO passed under Section 143(3) r.w.s. 153C of the Act, for the A.Y. 2014-15 is found to be beyond jurisdiction and is liable to be quashed. 6.6 In view of the above, the grounds no.1 & 2 of appeal are allowed…” 4. Aggrieved against the common appellate order, the Revenue is in appeal before us raising the following grounds of appeals: i. IT(SS)A No.17/Ahd/2025 for AY.2014-15 1. The Ld.CIT(A) has erred in law and on facts by quashing the assessment processing under section 153C, despite the facts that the additions made were based on incriminating seized digital data found during the search, which clearly fall within the ambit of material that justified the issuance of notice under section 153C. 2. The Ld.CIT(A) has erred in not deciding the appeal on merit. 3. The revenue craves leave to add/alter/armed and/on substitute any or all of the grounds of appeal. ii. IT(SS)A No.18/Ahd/2025 for AY.2015-16 1. The Ld.CIT(A) has erred in law and on facts by quashing the assessment processing under section 153C, despite the facts that the additions made were based on incriminating seized digital data found during the search, which clearly fall within the ambit of material that justified the issuance of notice under section 153C. 2. The Ld.CIT(A) has erred in not deciding the appeal on merit. 3. The revenue craves leave to add/alter/armed and/on substitute any or all of the grounds of appeal. Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 6– 5. The Ld.CIT.DR appearing for the Revenue in support of the grounds of appeals argued that Ld.CIT(A) is not correct in quashing the Assessment Orders wherein satisfaction was recorded well within the time relating to the Asst. Years 2014- 15 and 2015-16. 6. Per Contra, the Ld.Counsel Shri Aseem Thakkar appearing for the Assessee submitted that the searched Assessing Officer for the person and the other person (namely the assessee herein) are the same Assessing Officer. Hence, there was no transfer of seized materials to other Assessing Officer. However, the Assessing Officer recorded his satisfaction note and issued notice u/s.153C of the Act on 04.08.2022, taking note of the search action taken place on 15.10.2019. The Ld.Counsel also produced before us a copy of the notices issued u/s.153C of the Act dated 04.08.2022. As per the satisfaction note, the proceedings u/s.153C of the Act could have been initiated in the case of assessee for six years preceding the Asst. Year 2023-24 i.e for the Asst. Years 2017- 18 to 2022-23 only. However, the Assessing Officer reckoned the preceding Asst. years with a date of search and thereby issued notices for the Asst. Years 2014-15 to 2020-21. Thus, the Assessing Officer has no Jurisdiction to initiate the proceedings u/s.153C of the Act for the Asst. Years 2014-15 and 2015-16 whereas the Ld.CIT(A) following the Supreme Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 7– Court judgement in the case of Super Malls(P.) Ltd (Supra) held that consequential Assessment Orders framed by the Assessing Officer has no legs to stand, thereby quashed the Assessment Orders which is well within the provisions of Law, and the findings of the Ld.CIT(A) does not require any interference and the Revenue appeals are liable to be dismissed. In support, the Ld.Counsel also submitted the Co- ordinate Bench decision in the case of DCIT –Vs- Suraj Ltd. which has considered the above provision and thereby requested to dismiss the Revenue appeals. 7. We have considered the rival submission and perused the materials available on record. This issuance of notice for the six preceding Asst. Years in the case of non-searched person u/s.153C of the Act is no more resintegra following the Supreme Court Judgements in the case of Super Malls(P.) Ltd.(cited Supra) and CIT –Vs- Jasjit Singh(2023) 155 taxmann.com 155(SC) which has been duly followed by the Co-ordinate Bench of this Tribunal in the case of DCIT –Vs- Suraj Limited reported in (2024) 165 taxmann.com 410 wherein it was held as follows: “…12. As per provision of Section 153C of the Act, if the AO of the searched person is satisfied that any books of accounts or documents or assets belong or pertain to other than the searched person (other person), then such books of accounts or documents or assets shall be handed over by the AO of the searched person to the AO of the other person. In the present case the AO of the searched person and the AO Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 8– of the other person was same. Therefore, there was no requirement of actual handing over of the seized documents belonging to the assessee to any other AO. Nevertheless, in order to assume jurisdiction on the case of the other person it is necessary for the common AO to record his satisfaction that the seized document pertains/belongs to the other person. Until and unless he records such satisfaction, he can't assume the jurisdiction to initiate proceedings u/s 153C of the Act in the case of other person. The condition of recording satisfaction note by the AO of the searched person was, therefore, required to be mandatorily complied in this case as well. 13. In the course of hearing, vide order sheet note dated 11.09.2023, the Ld. CIT.DR was required to produce the satisfaction note of the AO of the searched person while handing over the documents found during the search and relating to the assessee, as prescribed by law under Section 153C of the Act. The satisfaction note as recorded by the AO of the searched person was not produced by the Revenue and a reply of the AO [DCIT, Central Circle-1(3)] dated 13.10.2023 was filed, which is reproduced below: \"2. It is submitted that in the case of Suraj Group of cases, a search action u/s 132 of the Act was carried out on 18.12.2013 M/s. Suraj Limited being one of the entities of the group was also covered in the search. During the course of search proceedings, various indiscriminating documents belonging to the assessee i.e. M/s. Suraj Limited was found and seized. Accordingly, the centralization was recommended by the Investigation Officer to DCIT Central Circle 1(3), Ahmedabad vide DGIT(Inv) Ahmedabad's order No. DGIT(Inv.)/HQ/Ahd/Centr-Suraj Gr/2013-14 dated 07/03/2014. Further, in the centralization proposal itself, M/s. Suraj Limited was recommended to be assessed u/s153C of the Income Tax Act based on post search findings. Thus, deriving clear cut satisfaction drawn by the Investigation Officer, seized material and based on specific recommendation of action under section 153C of the IT Act proceedings u/s 153C were initiated as per the law by issuing notice u/s. 153C of the I.T. Act following due procedure. Satisfaction drawn by the Investigation Officer, facts narrated in the appraisal report on seized material and specific recommendations for initiation of proceedings u/s 153C of the act, are enclosed to this effect. Therefore, the AO has taken due cognizance of specific recommendations as is evident from the additions made in the assessment order. The AO has also adopted the line of investigation as recommended by the Investigation Officer while processing action u/s 153C of the act. However, as the matter of assessment is very old and due to piling of assessment records one over the other, there is a possibility of misplacement of specific folder / page deriving satisfaction under section 153C of the act as the AO of the searched assessee and Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 9– the AO over M/s Suraj Limited was one and the same. Such non availability or misplacement may kindly not to be construed as non-deriving of satisfaction u/s 153C of the act 2.1 Further it is humbly submitted that issues related to M/s Suraj Limited very thoroughly elaborated in the appraisal report are binding on the Assessing Officer of the Central Circle and the AO is duty bound to follow the same unless he/she finds any deviation based on specific investigations carried out. But in this case, no such deviation even, was suggested by the AO which clearly shows that AO had been very much clear about Satisfaction drawn by the Investigation Officer, facts narrated in the appraisal report on seized material and specific recommendations for initiation of proceedings u/s 153C of the act. Therefore, the order of the AO may kindly be held valid and in accordance with law. 2.2 Still efforts are on to trace that specific folder / page deriving satisfaction under section 153C of the act as the AO of the searched assessee and the AO over M/s. Suraj Limited was one and the same and there is a possibility that it might be tagged together at one specific folder kept separately for action u/s 153C of the act or may be tagged with other cases of the same group.\" 14. Even if we accept the contention of the Revenue that there was no requirement of transfer of seized documents from one AO to another in this case, the proceeding under Section 153C of the Act could have been initiated only after recording of satisfaction by the AO of the searched person. It has been held by the Hon'ble Supreme Court in the case of Super Malls (P.) Ltd. v. Pr. CIT [2020] 115 taxmann.com 105/273 Taxman 556/423 ITR 281 (SC) that before issuing notice under Section 153C of the Act the AO of the searched person must be satisfied that any document seized or requisitioned belongs to a person other than the searched person. The recording of satisfaction by the AO of the searched person is sine qua non to initiate proceeding u/s 153C of the Act, even in a case where the AO of the searched person and AO of the other person is common. To quote from the order of the Hon'ble Supreme Court: \"6. This Court had an occasion to consider the scheme of Section 153C of the Act and the conditions precedent to be fulfilled/complied with before issuing notice under Section 153C of the Act in the case of Calcutta Knitwears (supra) as well as by the Delhi High Court in the case of Pepsi Food Pvt. Ltd. (supra). As held, before issuing notice under Section 153C of the Act, the Assessing Officer of the searched person must be \"satisfied\" that,inter alia, any document seized or requisitioned \"belongs to\" a person other than the searched person…. Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 10– 6.1…. At the same time, the satisfaction note by the Assessing Officer of the searched person that the documents etc. so seized during the search and seizure from the searched person belonged to the other person and transmitting such material to the Assessing Officer of the other person is mandatory. However, in the case where the Assessing Officer of the searched person and the other person is the same, it is sufficient by the Assessing Officer to note in the satisfaction note that the documents seized from the searched person belonged to the other person. Once the note says so, then the requirement of Section 153C of the Act is fulfilled. In case, where the Assessing Officer of the searched person and the other person is the same, there can be one satisfaction note prepared by the Assessing Officer, as he himself is the Assessing Officer of the searched person and also the Assessing Officer of the other person. However, as observed hereinabove, he must be conscious and satisfied that the documents seized/recovered from the searched person belonged to the other person. In such a situation, the satisfaction note would be qua the other person. The second requirement of transmitting the documents so seized from the searched person would not be there as he himself will be the Assessing Officer of the searched person and the other person and therefore there is no question of transmitting such seized documents to himself. (Emphasis supplied.) 15. Thus, the recording of satisfaction by the AO of the searched person is a mandatory requirement for initiation of proceeding under Section 153C of the Act. It is only by recording the satisfaction that the common AO assumes the jurisdiction to issue notice u/s 153C of the Act in respect of the other person. Further, it is only on the date of recording of satisfaction that the AO of the other person will assume the jurisdiction to initiate proceeding under Section 153C of the Act in respect of the other person. Therefore, the submission of the Revenue that only the date of search needs to be applied to calculate the time limit in the present case, is neither correct nor in accordance with the provision of law as well as the decision of Hon'ble Supreme Court in the case of Super Malls (P.) Ltd. (supra). It doesn't matter whether the assessee is related or unrelated to the searched group. The date of recording of satisfaction by the AO of the searched person will be the relevant date to initiate the proceeding under Section 153C of the Act and the time limit of six assessment years has to be computed with reference to the date of recording of satisfaction by the AO of the searched person. The seized documents pertaining to the other person will be deemed to be transferred to the AO of the other person on the date of recording of satisfaction by the common AO. Since, the Revenue has not produced the satisfaction note recorded by the common AO in this case, one can only presume that satisfaction was recorded Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 11– immediately prior to the issue of notice under Section 153C of the Act. As per standard practice of the Department the notice u/s 153C is issued immediately after recording of satisfaction. Since the notice under Section 153C of the Act was issued on 11.01.2016 in this case, the year in which the satisfaction note was recorded and the documents were deemed to be transferred to the AO of the present assessee has to be taken as the financial year 2015-16 relevant to A.Y. 2016-17. Therefore, the six preceding years for which proceeding under Section 153C of the Act could have been validly initiated in this case were A.Ys. 2015-16 to 2010-11 only. The proceeding under Section 153C of the Act for A.Y. 2008-09 as initiated in this case is, therefore, not found within the permissible limit of 6 years from the date of deemed handing over of documents by the AO of the searched person to the AO of the other person. 16. It will be relevant to refer to first proviso of Section 153C of the Act which explains the date of initiation of search for the proceedings under Section 153C of the Act as under: Provided that in case of such other person, the reference to the date of initiation of the search under section 132 or making of requisition under section 132A in the second proviso to sub-section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person : The above proviso makes it crystal clear that the date of initiation of search as referred in 2nd Proviso of Section 153A of the Act shall be construed as reference to the date of receiving the books of accounts or documents or assets seized or requisitioned by the AO having jurisdiction over such other person. Thus, the date of receiving of the books of accounts by the AO of the other person shall be treated / deemed as date of search and six years preceding to that year will be construed as the relevant years for which proceedings under Section 153C of the Act can be initiated in respect of such other person. 17. The Hon'ble Delhi Court has categorically held in the case of Pr. CIT (Central-1) v. Ojjus Medicare (P.) Ltd. [2024] 161 taxmann.com 160/465 ITR 101 (Delhi), that in case of a search assessment undertaken under Section 153C of the Act, the previous year of search would stand substituted by the date or the year in which the books of accounts / documents and assets seized are handed over to the jurisdictional AO of the other person as opposed to the year of search which constitutes the basis for an assessment under Section 153A of the Act. Thus, the block period for the proceedings under Section 153C of the Act has to be computed from the date of receipt of books of Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 12– accounts or documents by the AO of the non-searched person. This principle has been upheld by the Hon'ble Supreme Court in the case of Jasjit Singh (supra), wherein it was held that in case of other person the period for which they were required to file returns u/s 153C of the Act, commenced only from date when materials were forwarded to their jurisdictional Assessing Officers. The Apex Court categorically held that the proviso to section 153C(1) catered not merely to question of abatement but also with regard to date from which six year period was to be reckoned, in respect of which returns were to be filed by third party whose premises were not searched and in respect of whom specific provision of section 153C was enacted. 18. In view of the above legal position, there is no ambiguity that for the proceedings under Section 153C of the Act, the year of search shall be substituted by the year of receipt of books or documents by the AO of the other person and thereafter the period of six years has to be counted backwards from that year. In the instant case, seized documents were deemed to be transferred to the common AO on the date of recording of satisfaction by the common AO in F.Y. 2015-16 relevant to A.Y. 2016-17. Therefore, the proceeding u/s 153C could have been validly initiated in the case of the assessee for the six years preceding the A.Y. 2016-17 i.e. for the A.Y.2015-16 to A.Y.2010-11 only. 19. In view of the above facts, we are of the considered opinion, that the AO had no jurisdiction to initiate proceeding under Section 153C of the Act for the A.Y. 2008-09. As the issue of jurisdiction goes to the root of the matter the order of the AO passed under Section 153C r.w.s. 143(3) of the Act, is found to be beyond jurisdiction and is liable to be quashed…” 8. Respectfully following the above decisions we have no hesitation in holding that the notices issued u/s.153C of the Act for the Asst. Years 2014-15 and 2015-16 are found to be beyond jurisdiction as on the date of handing over of seized materials and recording of satisfaction Note on 04.08.2022. In that case assessments ought to have been reopened for six Asst. Years namely 2017-18 to 2022-23 in the case of the assessee, being non-searched person. Thus, the findings Printed from counselvise.com IT(SS)A Nos.17 & 18/Ahd/2025 ACIT vs. Bipin Amarcahnd Gala Asst.Years –2014-15 & 2015-16 - 13– arrived by the Ld.CIT(A) does not require any interference and the Grounds raised by the Revenue are devoid of merits. 9. In the result, both the appeals filed by the Revenue are hereby dismissed. This Order pronounced in Open Court on 28.07.2025 Sd/- Sd/- (MAKARAND VASANT MAHADEOKAR) (T.R. SENTHIL KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER (True Copy) Ahmedabad; Dated 28.07.2025 Manish, Sr. PS TRUE COPY आदेश कᳱ ᮧितिलिप अᮕेिषत/Copy of the Order forwarded to : 1. अपीलाथᱮ / The Appellant 2. ᮧ᭜यथᱮ / The Respondent. 3. संबंिधत आयकर आयुᲦ / Concerned CIT 4. आयकर आयुᲦ(अपील) / The CIT(A)- 5. िवभागीय ᮧितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Surat/Ahmedabad 6. गाडᭅ फाईल / Guard file. आदेशानुसार/ BY ORDER, उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad/Surat Printed from counselvise.com "