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Judgment
These assessee's seven appeals IT A No s. 2 673 to 2679/Del/2026 ; for assessment ye ars 2014-15 to 2020-21, ar ise against Commissioner of Inco me Tax (Appeals)-27 (in short, 'CIT(A)'), Ne w Delhi's o rders all dated 14.01.2026, passe d in case Nos. CIT(A), 10895/2013-14, 10453/2014-15, 10943/2015-16, 11226/2016-17, 10514/2017-18, 10991/2018-19, 10706/2019-20, passed u/s 271(1)(c) & 271AAC (1) o f the Income Tax Act, 1961; hereinafter referred to as, 'the Act', respectively.
Heard both the parties. Case files perused.
It emerges at the outset that bo th the learned lower authorities' have Invoked their respective penalty proceedings, be it u/s 271(1)(c) or u/s 271AAC of the Act; as the case may be, against the assessee thereby holding him to have derived undisclosed income and expenditure etc., found and de ducted during the course of search carried out on 23.12.2019.
Learned counsel at the outset files on recor d the tribunal's common order in the assessee's correspo nding арреals IT A No. 1163 to 1168 /De l/2025 (involving all assessment years except 2015-16) quashing the corresponding “quantum” assessme nts itself for want of a valid approval u/s 153D of the Act. This clinching factual position has gone unrebutted from the Revenue side. Coming to the remaining assessment year, 2015-16 as well, we noticed that the same invo lves some estimated commission and interest inco me etc than that based on any actual e vide nce.
It is in light of all these clinching developments that we hereby conclude that be it on it legality or on merits, the Revenue's stand herein does no t deserve to be accepted once the impugned corresponding quantum assessments stand quashe d. The impugned penalties have no le gs to stand ther efore in very terms. The same invo lving assessment year 2015 -16 also stands deleted o n merits as we ll in foregoing terms.
These assessees' seven appeals ITA Nos. 2673 to 2679/Del/2026 are allowed. A copy of this common order be place d in the respective case files.