Further, the third appeal being ITA 458/SRT/2026 is the appeal filed by assessee against the original order dated 16.08.2023 passed by learned Ld. 20,12,245/- as income u/s 56(2)(viib) and completed assessment u/s 143(3) vide order dated 09.12.2016. CIT(A) passed order dated 16.08.2023 u/s 250 disposing assessee’s appeal taking wrong facts into account (as discussed in later part of this order). Additionally, the assessee has also filed appeal ITA 458/SRT/2026 against original order dated 16.08.2023 passed by Ld. In these circumstances, we are unable to sustain the impugned appellate order passed by Ld.