Multi-year batch: DVO deletion, profit-rate consistency, 69A confirmations (ITAT Lucknow)

Order: ITA Nos. 347-353, 398, 399, 402, 405 & 460/Lkw/2025 with ITA Nos. 557 & 608/Lkw/2024 (ITAT Lucknow), Assessment Years 2014-15 to 2022-23, pronounced 11.12.2025.

Facts

The batch spans assessee appeals, Revenue appeals and cross-objections across AYs 2014-15 to 2022-23, covering valuation differences, profit-rate estimation, cash-credit and section 40A(3)/80G issues.
For AY 2021-22 the cross-objection contested a Rs.9,41,800 addition based on the valuation officer's figure against the disclosed property value, already sustained by the Commissioner (Appeals).
For AY 2022-23 the Revenue contested the scaling down of the net profit rate from 11% and two section 69A additions of Rs.7,81,000 (agricultural income shown) and Rs.35,31,800, while the assessee contested a Rs.4,75,445 valuation-difference addition.

Holdings

The Rs.9,41,800 valuation-difference addition for AY 2021-22 was directed to be deleted.
For AY 2022-23 the Assessing Officer was directed to accept the disclosed net profit rate, consistent with the view taken for AY 2014-15 where parity of facts was unrebutted.
The Commissioner (Appeals)'s order on both 69A additions was held just and fair on the law and facts, and the Tribunal declined to interfere.
The Rs.4,75,445 valuation issue was restored to the Assessing Officer for de-novo verification, the related approval-validity dispute being moot since no addition survived for the year.
Overall: assessee appeals for 2014-15 to 2019-20 allowed and Revenue appeals dismissed for statistical purposes; the 2020-21 cross-objection and 2021-22 appeals partly allowed on both sides; both 2022-23 appeals dismissed.

Why a client would care

In a multi-year sweep the Tribunal decides year by year on the record available: valuation and rate issues can be won outright, thin-record issues go back for verification, and confirmed additions survive only where the appellate order is just and fair.

Questions clients ask

Q1. For AY 2021-22 the valuation officer’s figure exceeded the disclosed property value by Rs.9,41,800. What was the result?

The addition was directed to be deleted.

Q2. The Assessing Officer applied an 11% net profit rate for AY 2022-23. Did that stand?

The Assessing Officer was directed to accept the disclosed net profit rate, consistent with AY 2014-15 where the parity of facts was unrebutted.

Q3. What happened to the two section 69A additions?

The Commissioner (Appeals)’ order on both was held just and fair on law and facts, and the Tribunal declined to interfere.

Disclaimer

This note summarises a Tribunal order for general information. It is not professional advice and does not predict the outcome of any other case. Tax and company-law positions depend on facts and dates; take a written opinion before you act. Harun Raaj & Associates is a Chartered Accountants firm in Visakhapatnam.

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