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AO') orders passed under section 147 of the Act, both the orders dated 31.03.2022.

2. The brief facts of the case is that both the appeals have same nature of fact and have a common issue, so both the appeals have taken together, heard together and for convenience disposed of by a common order. ITA 1706/Mum/2025 A.Y. 2014-15 is taken as lead case and the decision rendered therein shall apply mutatis mutandis to other appeal.

3. The brief facts of the case are that the assessee is engaged in business of real estate development. During the impugned assessment year the assessee derive income from business or professional. The assessee has filed the return and declaring income nil, after showing the current year loss of Rs.86,015/-. The assessment was completed u/sec. 143(3). Subsequently, the case of the assessee was reopened by issuance notice u/sec. 148 of the Act. A survey u/sec. 133A of the Act was conducted in the case of M/s. Sikkim Ferro Alloys Ltd. and its group concern on 16.09.2016. On related to this survey the assessee case was reopened. The revenue has found that the assessee had made a transaction with M/s. Parekh Aluminex Ltd. (PAL) related to its land at Wada. The PAL was agreed to purchase the Wada land from the assessee. The assessee had made a memorandum of understanding with the PAL and as per the understanding amount received by Trisons Agency, Alioth Infrastructure P. Ltd., Manohar Manek Alloys P. Ltd. from M/s. PAL has been agreed to adjust against the sale price of the Wada land. The amount which has been agreed to be adjusted as aforesaid would be payable by Trison Agency Alloys Infrastructure P. Ltd., Manohar Manak P. Ltd. to the Company and the balance price of the land from PAL would be executed ITA No.1697 and 1706/Mum/2024 Shree Rajlaxmi Infrastructure P. Ltd.