IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY, ACCOUNTANT, MEMBER ITA no.370/Nag./2022 (Assessment Year : 2011–12) Tirupati Coal Block no.5–64, Utkarsh Nirman Mangalwari Bazar, Sadar, Nagpur 440 001 PAN – AAFFT7608E ................ Appellant v/s Principal Commissioner of Income Tax Nagpur–2, Nagpur ................ Respondent Assessee by : None Revenue by : Shri Kailash C. Kanojiya Date of Hearing – 12/08/2024 Date of Order – 12/08/2024 O R D E R PER V. DURGA RAO, J.M. The present appeal has been filed by the assessee challenging the impugned order dated 19/02/2021, passed by the learned Principal Commissioner of Income Tax, Nagpur–2, [“learned PCIT”], for the assessment year 2011–12. 2. In its appeal, the assessee has raised following grounds:– “The order passed u/s 263 by the Learned Principal Commissioner of Income, is wrong. illegal and opposed to facts of the instant case. 2. The Learned PCIT failed to appreciate the facts of the case and passed orders which are opposed to the facts of the case and is erroneous in law.