9911796707
TMI Blog2022 (7) TMI 394X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment years 2013-14 and 2014-15 respectively. The assessee has also preferred an appeal in ITA No. 59/DEL/2020 against the order of the CIT(A) -26, New Delhi dated 06.11.2019 pertaining to A.Y 2015-16. 2. The captioned appeals have common issues and the underlying facts in issues are identical. Therefore, we are disposing off all the appeals by this common order for the sake of convenience and brevity. 3. Briefly stated, the facts of the case are that a search and seizure operation u/s 132 of the Income-tax Act, 1961 [hereinafter referred to as 'The Act'] was carried out on Dua Group of cases on 25.04.2014 and simultaneously, premises of the assessee and his son Shri Himanshu Kohli were also searched. Various incriminating docu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9436 6. The Assessing Officer, accordingly, made addition of gross profit of 30% of unaccounted sale in respective Assessment Years and, further made addition on account of investment in these unaccounted transactions after reducing the gross profit added and further made additions, 7. The Assessing Officer also made addition of remaining 70% of gross profit and peak investment on protective basis observing that substantive addition shall be made in the hands of Shri Pawan Kumar Dua. 8. Additions were challenged before the ld. CIT(A). 9. The ld. CIT(A) was convinced that since the addition has been made on substantive basis in the hands of Shri Pawan Kumar Dua, the same was deleted from the hands of the assessee. Addition on account of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n his reply filed by the assessee before the ACIT, Central Circle - 28, New Delhi, which is exhibited at pages 67 to 86 of the paper book, at Para 4.2, which is at page 77 of the paper book, the assessee has specifically mentioned that majority of purchase/sale transactions were of Dua group in respect of which his son Shri Himanshu Kohli had received commission and at Para 4.4, which is at page 79 of the paper book, the assessee has again mentioned that 30% of the transactions represents unaccounted business looked after by Shri Himanshu Kohli and at para 4.6 which is at page 80 of the paper book, the assessee categorically stated that Shri Himanshu Kohli was doing metal business on commission basis for Dua group. While doing it for them, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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