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Judgment
These assessee’s three appeals ITA Nos.6316, 6317 & 6318/Del/2026 for assessment years 2015-16 to 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s orders, all dated 29.04.2026, having DINs and orders no. ITBA/NFAC/S/250/2026-27/1088701683(1), 1088702056(1) & 1088702705(1), involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It transpires during the course of hearing that there is hardly much a need for the tribunal to deal with the assessee’s entire factual matrix at length so far as the correctness of both the learned lower authorities’ identical action applying NP @ 6.11% each on the alleged export sales of Rs.6,43,50,048/-; 6,41,39,900/- & 7,28,64,761/-; assessment year-wise, is concerned. This is for the precise reason that he already claims to have disclosed his export sales in regular books to the tune of Rs.6,44,46,334/-, Rs. 6,41,38,063/- and Rs.7,28,75,849/- having NP @ 8.52%, 7.48% and 9.03%; respectively. That being the case, the Revenue seeks to buttress the point that the assessee had filed its aforesaid section 139(1) return declaring the latter turnover with the PAN ADIPR2292L whereas the PAN used in the three assessment years herein is ADIPR2293M; and therefore, the impugned net profit deserves to be upheld.
I have given my thoughtful consideration to the assessee’s and the Revenue’s foregoing respective vehement contentions. I am of the considered view that the instant issue requires the learned Assessing Officer’s afresh factual verification and reconciliation so as to avoid any double addition in the assessee’s hands i.e. the turnover already declared in the regular books, vis-à-vis, that the one added in the impugned assessments. I accordingly restore the assessee’s instant three identical appeals back to the learned Assessing Officer to carry out the necessary consequential exercises within three effect opportunities of hearing. It is made clear at the cost of repetition that there should not be any double addition qua the assessee’s export sales; in consequential proceedings.
No other ground or argument has been pressed.
These assessee’s three appeals ITA Nos.6316, 6317 & 6318/Del/2026 are allowed for statistical purposes. A copy of this common order be placed in the respective case files.