SHALIMAR CORP LTD.,LUCKNOW, UTTAR PRADESH V. PCIT(CENTRAL), DELHI-3, NEW DELHI

ITA 1548/DEL/2025

AI Insights

The case involves two appeals by Shalimar Corp Ltd. against the orders of the Principal Commissioner of Income Tax (PCIT), which were passed under section 263 of the Income Tax Act, 1961, for the assessment years 2013-14 and 2014-15. The PCIT's orders were based on the grounds that the original assessment orders were erroneous and prejudicial to the interests of the revenue. However, the Tribunal noted that the original assessments had been completed with the prior approval of the Addl. Commissioner of Income Tax under section 153D, which was not considered by the PCIT in his revisionary orders. The Tribunal referenced several judicial precedents supporting the view that once an assessment order is passed with the prior approval under section 153D, it cannot be revisited under section 263 unless the approval itself is found to be erroneous.

• Duration Of Justice: 1 year(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-03-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Delhi
• Assessment Year: 2014-2015
• Appeal Filed On: 13-03-2025
• Other Referred Cases: PCIT vs. Prakhar Developers (P) Ltd., Ramamoorthy Vasudevan vs. PCIT, Dhariwal Industries Ltd. v. CIT, Trinity Infraventures Ltd. v. DCIT, Devender Kumar Gupta vs. PCIT, M/s Tinna Trade Ltd. vs. ACIT, Venizzia Golf City vs. PCIT
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ANKUSH KALRA
• Assessee Lawyers: SUBHASH AGARWAL
• Keywords: Set aside; Question of law; Document seized; Documents seized; Retraction; Search and seizure; Assessment record; Competent authority; Revision of order
• Section: 143(3); 263; 153A

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘E’: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTNAT MEMBER ITA Nos.1546 & 1548/DEL/2025 [Assessment Years: 2013-14 & 2014-15] Shalimar Corp Ltd. 11th Floor, Shalimar Titanium, Vibhuti Khand, Gomti Nagar, Lucknow, Uttar Pradesh-226010 Vs PCIT, Central-3, Room No.325, 3rd Floor, Income Tax Building E-2, ARA Centre, Jhandewalan Extension, New Delhi-110055 PAN-AADCS9234L Assessee Revenue Assessee by Shri Subhash Agarwal, Adv. Revenue by Ms. Ankush Kalra, Sr. DR Date of Hearing 26.02.2026 Date of Pronouncement 27.02.2026 ORDER PER AMITABH SHUKLA, AM, These two appeals filed by the assessee are against orders both dated 31.03.2024 of learned Principal Commissioner of Income Tax, New Delhi, [hereinafter referred to as ‘ld. PCIT] passed under section 263 of the Income Tax Act, 1961 pertaining to Assessment Year and 2013-14 and 2014-15. The word ‘Act’ herein this order would mean Income Tax Act, 1961. 2. As both the appeals are on the commons issue of exercise of revisionary authority under section 263 of the Act by the PCIT, for the purposes of Printed from counselvise.com ITA No.1546/Del/2025 Page 2 of 13 convenience both the appeals were heard together and are being adjudicated by this common order. Since, facts are identical, decision taken in ITA No.1546/Del/2025 shall apply mutatis mutandis in ITA No.1548/Del/2025. 3. At the outset, we have noted that the Registry had identified delay of 286 days in filing of appeal for AY 2013-14. Explaining reasons for the delay, it has been submitted that the revisionary order was received on e-mail and the attendant staff was on a sick leave as a result of which the order could not be timely acted upon. The ld. Counsel pleaded that the delay be condoned. The ld. DR objected to the condonation of the delay. We are conscious that no litigant benefits by delaying its matters. Accordingly, we proceed to condone the delay and adjudicate this appeal, subject to payment of Rs.5,000/- by the assessee within one month of the receipt of this order to the Prime Minister Relief Fund. A receipt of the payment shall be made available to the ld. AO within one week of its payment. 4. The grounds of appeal raised in ITA No.1546/Del/2025 are as under:- 1. For that on the facts and in the circumstances of the case, the order passed by the Ld. Principal CIT u/s 263 of the Act is bad in law and is liable to be quashed. 2. For that the Ld. PCIT was not justified in holding that the assessment order passed u/s. 153A dated 17.11.2021 is erroneous and prejudicial to the interest of the revenue though the A.O. had completed the assessment after due enquiries and application of mind and no prejudice was caused to the revenue. Printed from counselvise.com ITA No.1546/Del/2025 Page 3 of 13 3. The Ld. PCIT failed to appreciate that the alleged transactions in connection with Gold Account as reflected in the seized documents were not relating to the A.Y.: 2013-2014. 4. Without prejudice to the above, the Ld. PCIT ought to have considered that the income earned from On-Money, which was added back by the A.O. during the course of assessment proceedings u/s. 153A, was invested in gold and, as such, no separate addition was called for. 5. The grounds of appeal raised in ITA No.1548/Del/2025 are as under:- 1. For that on the facts and in the circumstances of the case, the order passed by the Ld. Principal CIT u/s 263 of the Act is bad in law and is liable to be quashed. 2. For that the Ld. PCIT was not justified in holding that the assessment order passed u/s. 153A dated 17.11.2021 is erroneous and prejudicial to the interest of the revenue though the A.O. had completed the assessment after due enquiries and application of mind and no prejudice was caused to the revenue. 3. For that on the facts and in the circumstances of the case, the Ld. PCIT was not justified in directing the A.O to carry out thorough and detailed enquiries on the issue of undisclosed investment in gold of Rs. 13,91,26,000/-. 6. The assessee has also raised additional ground of appeal challenging exercise of revisionary authority u/s 263 by the Ld. PCIT. It has been contested that as the order u/s 153A dated 17.11.2021 was passed with the approval of JCIT, Central Range-8, the ld. PCIT, was ousted of his jurisdiction under section 263 to exercise any revisionary authority. 7. We have heard rival contentions in the light of material available on records. The only controversy seminal to this appeal in ITA No.1546/Del/2025 is regarding the invocation revisionary authority section 263 of the Act by the ld. PCIT. The ld. Counsel for the assessee has drew our attention to the last Printed from counselvise.com ITA No.1546/Del/2025 Page 4 of 13 page of the order u/s 153A dated 17.11.2021, clearly alluding that the order was passed with the approval of JCIT, Central Range-8, Vide F. No.JCIT/CR- 8/2021-22/1516 dated 17.11.2021 under section 153D of the Act. The ld. Counsel contended that the Ld. PCIT was ousted of his jurisdiction under section 263 in this case. In support Reliance was placed upon the decision of this Tribunal in ITA No.1503/Del/2024 dated 23.11.2025 in the case of Shri Aditya Gupta. It was stated that as its case is squarely covered by the above, the order under section 263 deserves to be quashed and set-aside. 8. We have noted that the this Tribunal in ITA No.1503/Del/2024 dated 23.11.2025 has held as under “.........4. Heard rival submissions, perused the orders of the authorities below and the case law relied on. In ground nos. 2 & 2.1 of grounds of appeal the assessee contends that since the assessment order u/s 143(3) was passed with the prior approval of Addl. CIT u/s 153D of the Act such assessment order could not have been validly revised u/s 263 of the Act by the PCIT. We find that this issue has been decided by various benches of the Tribunal following the decisions of various High Courts. 5. The Hon’ble Madhya Pradesh High Court in the case of PCIT vs. Prakhar Developers (P) Ltd. (supra) held as under: “7. Learned counsel for the appellant failed to answer the query made by this Court whether order passed by the Pune Bench in the case of RAMAMOORTHY VASUDEVAN (SUPRA) was challenged before the High Court or Supreme Court on the issue of jurisdiction under section 263 of the Act. Learned counsel submits that she could not lay her hands any order / judgment passed by the High Court as well as by the Supreme Court on this issue. In the case of RAMAMOORTHY VASUDEVAN (SUPRA), in a similar facts and circumstances, reliance has been placed on judgments delivered by the Pune Bench of Tribunal in the case of DHARIWAL INDUSTRIES LTD. v. CIT [IT Appeal Nos. 1108 to 1113/PUN/2014], Lucknow Bench in the case of MEHTAB ALAM Printed from counselvise.com ITA No.1546/Del/2025 Page 5 of 13 v. AC IT [IT Appeal Nos.288 to 294/Lkw/2014], Hyderabad Bench of the Tribunal in the case of CH. KRISHNA MURTHY v. ACIT [IT Appeal No.766/Hyd/2012] and one of the judgment passed by the High Court of Judicature at Allahabad in the case of CIT v. DR. ASHOK KUMAR [IT Appeal No. 192 of 2000] and Hyderabad Bench of Tribunal in the case of TRINITY INFRA VENTURES LTD. v. DCIT [IT Appeal No.584/H/2015] and consistently held that once the order under Section 143(3) r/w section 153A of the Act has been passed after taking prior approval of the AClT under section 153D of the Act, then the jurisdiction under section 263 of the Act cannot be invoked. Therefore, the view taken by the Co- ordinate Bench of the Appellate Tribunal had attained finality. Hence, the ITAT, Indore has not committed any error of law by following the same view. 8. Even otherwise, as per section 263 of the Act, the Principal Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act and if he considers that any order passed therein by the Assessing Officer, is erroneous in so far as it is prejudical to the interests of the Revenue, he may make enquiry as he deems necessary, pass such order thereon as the circumstances of the case justify. For passing any order under sections 143(3) & 153A of the Act, prior approval of Joint Commissioner is required under section 153A of the Act, or Principal Commissioner or Commissioner as the case may be. Therefore, once prior approval had already been taken by the Assessing Officer and accepted the return submitted by the assessee, then the same authority cannot exercise the power under Section 263 of the Act to reverse the order of Assessing Officer.” 6. The Hon’ble Allahabad High Court in the case of CIT vs. Dr. Ashok Kumar in ITA No.192/2000 held as under: - “3. These appeals were admitted on the question of law, which we have corrected as follows:- \"Whether on the facts and in the circumstances of the case, the Tribunal was justified in interfering with the order of the Commissioner of Income Tax, Under Section 263 of the Income Tax Act 1961 for the assessment years 1991-92 to assessment years 1995-96?\" 4. We have gone through the order of Assessing Officer, Commissioner Income Tax (A) and Income Tax Appellate Tribunal and find that the ITAT has considered the reasons given by the Printed from counselvise.com ITA No.1546/Del/2025 Page 6 of 13 CIT(A), and has found that the assessee had sufficiently explained the surrender of the income which he has subsequently retracted. 5. After assessments were completed, a raid was carried out, at the Nursing Home of the respondent assessee on 7.12.2004. Some incriminating documents of concealment of income, were discovered. The assessee was not present at the time of inspection. He appeared before the AO on 12.12.1994 and surrendered the proposed additions in the income for the relevant years. The respondent-assessee thereafter retracted his statement, by giving an explanation that he did not have access to his accounts books, when he had appeared on his own before the AO on 12.12.1994. On checking up the account books, he had found that the returns were accepted, on the accounts books prepared by him. 6. The Tribunal thereafter has observed as under:- \"5.1 The other relevant point to be noted is that CIT set aside the assessment order on the basis of incorrect reasons. As pointed out by the learned counsel, there was no material found during search about suppression of receipts for a.y. 199192 to 1994-95 nor the learned D.R. Was able to point out any such material which might have been ignored by the AO while framing the assessment and thus the vary basis for passing the impugned order goes away. The CIT also failed to point out as to why the AO failed to work out the amount of concealed income correctly, rather the AO had made the additions on estimate basis for all the assessment years though there was no seized material indicating suppression of receipts for these assessment years and for A.Y. 1995-96 the material found at the time of search had been analysed after necessary enquiries and assessment had been framed accordingly. 5.2 In the last it is also relevant fact that the AO was fully alive about, the facts of the case and that is why he got necessary approval of Addl. Commissioner before completing the assessment orders for all the assessment years and once that is not disputed by the Revenue than the CIT would not be justified in interfering in the approval accorded by the Addl. CIT for framing the assessment order and thus there was no case for setting aside the assessment orders for the assessment years in question. On the basis of facts and circumstances of the case I am of the opinion that Printed from counselvise.com ITA No.1546/Del/2025 Page 7 of 13 the impugned order is liable to be quashed accordingly. б. In the result, appeals are allowed.\" 7. Sri R.K. Upadhyay had relied upon Malabar Industrial Co. Ltd. Vs. Commissioner of Income Tax, (2000) 243 ITR 83 and Commissioner of Income Tax Vs. Kwality Twxtile Associate Pvt. Ltd., (2005) 272 ITR 371. In these cases the Supreme .Court and the Madras High Court have discussed the powers of CIT under Section 263 of the Act, to remand the matter. If the twin conditions namely that the order of AO sought to be revised is erroneous, and it also prejudicial to the interest of the revenue are satisfied the CIT can remand the matter to the file of A.O. 8. We find that the Tribunal has considered the relevant principles of law in interfering with the order of CIT. The Tribunal found that the assessee- respondent had sufficiently explained the retraction of his statement given on 12.12.1994. It also found that the CIT could not point out as to whether the AO had failed to work out the amount of concealed income correctly. The AO had made additions on estimate basis for all the assessment years. There was no material indicating suppression of receipts. 9. We find that the Tribunal has not committed any error of law in setting aside the order of CIT passed under Section 263 of Income Tax Act for the assessment year 1991-92 to 1995-96.” 7. The coordinate bench of Delhi Tribunal in the case of Devender Kumar Gupta vs. PCIT examined the validity of the order passed by the ACIT u/s 263 of the Act when an assessment order u/s 153A was passed after prior approval of the JCIT and the Tribunal held as under: - “5. Further, the Id. AR has submitted that in regard to the assessment orders under consideration for the four years, the assessment orders were passed u/s 153A of the Act after approval of Addl. CIT u/s 153D dated 24.09.2021. It was submitted by the ld. AR that an order which has been subject of approval u/s 153D of the Act cannot be subject to revision u/s 263 of the Act and for that the ld. AR has relied the following judicial pronouncements:- (i) Pr. CIT v. Prakhar Developers (P.) Ltd. [2024] 162 taxmann.com 48/299 Taxman 252 (Madhya Pradesh); (ii) Smt. Abha Bansal v. Pr. CIT [2021] 132 taxmann.com 231 (Delhi - Trib.); (iii) Gyan Infrabuild (P.) Ltd. v. Pr. CIT [2024] 162 taxmann.com 664 (Patna - Trib.); Printed from counselvise.com ITA No.1546/Del/2025 Page 8 of 13 (iv) BU Bhandari Schemes v. Pr. CIT [IT Appeal Nos. 637 to 641 (Pune) of 2018, dated 14-11-2018]; (v) Vishwa Infraways (P) Ltd. v. CIT (Central) [IT Appeal Nos. 596,597 & 599 (Pune) of 2015]; (vi) Rasi Kalal M. Dhariwal (HUF) v. CIT [IT Appeal Nos. 1102 to 1107 (Pune) of 2014]; (vii) Ramamoorthy Vasudevan vs. PCIT [IT Appeal Nos. 967 & 968 (Pune) of 2016]; (viii) Dhariwal Industries Ltd. v. CIT [IT Appeal Nos. 1108 to 1113 (Pune) of 2014, dated 23-12-2016]; (ix) Smt. Nama Chinnamma vs. Dy.CIT [IT Appeal Nos. 1150- 1157 (Hyd.) of 2015, dated 9-8-2017]; (x) Trinity Infraventures Ltd. v. Dy. CIT [IT Appeal Nos. 584-589 (Hyd.) of 2015, dated 4-12-2015]; (xi) S. Satyanarayana v. Syed Rasiuddin [IT Appeal No. 901 (Hyd.) of 2014]; (xii) Mehtab Alam v. Dy. CIT [IT Appeal No. 288 (Luck.) of 2014, dated 18-11- 2014]; (xiii) Dharmendra Kumar Bansal v. CIT [2014] 48 taxmann.com 53/152 ITD 406 (Jaipur – Trib.); & (xiv) ITA No.1503/Del/2024 CIT v. Dr. Ashok Kumar, Proprietor, S.S. Nursing Home [IT Appeal No. 192 of 2000, dated 68-2012] 6. This is countered by the Ld. DR by relying the order of Nagpur Bench of this Tribunal in Shrigopal Rameshkumar Sales (P.) Ltd. v. Assistant Commissioner of Income-tax [2022] 140 taxmann.com 628/196 ITD 107 (Nagpur - Trib.)/ITA No.162/Nag/2018 order dated 01.04.2022. 7. We have given thoughtful consideration to this aspect of the controversy and we find that a specific ground No.2 is raised by the assessee as follows: “2. That the assessment order passed u/s 153A r.w.s. 143(3) after getting an approval of Addl. Commissioner U/s 153D could not be revised u/s 263, hence Ld. PCIT exceeded his jurisdictional in invoking sec. 263 in respect of impugned asstt. order framed u/s 153A r.w.s. 153D.” Printed from counselvise.com ITA No.1546/Del/2025 Page 9 of 13 8. The assessment orders made it categorical that the same are passed with statutory approval of Addl. Commissioner of Income Tax, Central Range, Gurgaon communicated vide his office letter F.No. Addl.CIT(CR)/GGM/2021-22/664 dated 24.09.2021 in accordance with section 153D of the Income Tax Act. 9. We find that in the impugned order the Ld. PCIT has not taken account of the fact that the assessments were completed after prior approval of the competent authority. Thus, we are of the considered view that at the time of examining the issue as to if the assessment order is erroneous so far as prejudicial to the interest of the Revenue, the Ld. Revisional Authority is not only supposed to see the assessment record of AO, but also the record of the approval which as far as the revisional authority is concerned becomes “record” of the quasi judicial authority whose order is being examined by invoking the revisional jurisdictional. Therefore, without giving a finding that the prior approval u/s 153D was vitiated and was also erroneous so far as prejudicial to the interest of the Revenue, the assessment order independently cannot be held to be erroneous so far as prejudicial to the interest of the Revenue. 9.1 The catena of judicial pronouncements relied by the Ld. AR have also laid down the same proposition of law and we will like to refer specifically to the judgment of the Hon’ble Madras High Court in the case of Prakhar Developers (P) Ltd. (supra) where the Hon’ble Madras High Court has taken into consideration the fact that the Pune Bench order in the case of Ramamoorthy Vasudevan (supra) wherein it was held that the order passed by the PCIT is unsustainable due to lack of jurisdiction in invoking section 263 of the Act for the reason that the same was passed upon taking prior approval u/s 153A of the Act, was not challenged by the Department before the Hon’ble High Court or the Hon’ble Supreme Court and, thus, the Hon’ble Madras High Court in its judgment dated 01.04.2024 has held as follows: “8. Even otherwise, as per section 263 of the Act, the Principal Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act and if he considers that any order passed therein by the Assessing Officer, is erroneous in so far as it is prejudicial to the interests of the Revenue, he may make enquiry as he deems necessary, pass such order thereon as the circumstances of the case justify. For passing Printed from counselvise.com ITA No.1546/Del/2025 Page 10 of 13 any order u/s 143(3) & 153A of the Act, prior approval of Joint Commissioner is required u/s 153A of the Act, or Principal Commissioner or Commissioner as the case may be. Therefore, once prior approval had already been taken by the Assessing Officer and accepted the return submitted by the assessee, then the same authority cannot exercise the power u/s 263 of the Act to reverse the order of Assessing Officer.” 10. The judgment which the Ld. DR has relied is not applicable as in that judgment, this aspect was not actually examined at all and only for the reason that there also the impugned assessment order was passed u/s 153A of the Act, does not lay down a view contrary to the one we are relying above. 11. In the light of the aforesaid discussion, we are inclined to allow grounds No.2 & 3 for AYs 2015-16 and 2016-17; and ground no.3 in AYs 2017-18 and 2018-19. Consequently, the appeals are allowed and the impugned orders in respective years are quashed.” 8. Similarly in the case of M/s Tinna Trade Ltd. vs. ACIT the Delhi Bench of the Tribunal in ITA No.6117/Del/2016 dated 25.09.2024 held as under: - “g. Further, we find that the search assessment proceedings u/s 143(3) read with section 153C of the Act was framed on 26.03.2013 by Id DCIT, Central Circle, New Delhi after obtaining prior approval u/s 153D of the Act from Additional Commissioner of Income Tax, Central Range-2, New Delhi. On perusal of the order of the Id PCIT u/s 263 of the Act, we find nowhere in his order, the Id PCIT even whispers about the approval granted by the Additional CIT u/s 153D of the Act to be erroneous and prejudicial to the interest of the revenue. Without doing so, the Id PCIT could not assume revision jurisdiction u/s 263 of the Act. Reliance in this regard is placed on the decision of the Hon'ble Madhya Pradesh High Court in the case of PCIT V. Prakhar Developers Pvt. Ltd reported in 299 taxman 252 (MP). The very same view was also taken by the coordinate bench of this tribunal in the case of Devender Kumar Gupta V. PCIT reported in 166 taxmann.com 95 (Delhi Tribunal) vide order dated 30.08.2024. The relevant operative portion of the said tribunal order is reproduced herein below:- Printed from counselvise.com ITA No.1546/Del/2025 Page 11 of 13 \"9. We find that in the impugned order the Id. PCIT has not taken account of the fact that the assessments were completed after prior approval of the competent authority. Thus, we are of the considered view that at the time of examining the issue as to if the assessment order is erroneous so far as prejudicial to the interest of the Revenue, the Id. revisional authority is not only supposed to see the assessment record of AO, but also the record of the approval which as far as the revisional authority is concerned becomes \"record\" of the quasi judicial authority whose order is being examined by invoking the revisional jurisdiction. Therefore, without giving a finding that the prior approval u/s 153D was vitiated and was also erroneous so far as prejudicial to the interest of the Revenue, the assessment order independently cannot be held to be erroneous so far as prejudicial to the interest of the Revenue.\" 8. In view of the aforesaid decision the revision jurisdiction assumed by the PCIT u/s 263 of the Act fails on this count also.” 9. The ratios of the above decisions squarely applies to the facts of the assessee’s case since in the case on hand the assessment u/s 143(3) of the Act was completed on 12.05.2021 by the Assessing Officer with the prior approval u/s 153D of the Act of the Addl. Commissioner of Income Tax. Therefore, since the assessment was completed with the prior approval of Addl. CIT u/s 153D of the Act, the Ld. PCIT could not have revised the assessment order invoking the revisionary powers u/s 263 of the Act. Thus, respectfully following the above decisions, we quash the order passed by the Ld. PCIT u/s 263 of the Act for the AY 2019-20 by allowing ground nos. 2 & 2.1 of the grounds of appeal. Since we have quashed the order passed u/s 263 on a legal point, all other grounds raised by the assessee are not adjudicated as the same would become academic in nature at this stage...........” 9. We have further noted that this Tribunal in the case of Venizzia Golf City in ITA NO.1962/Del/2019 has also held the same view. We have noted that facts of the present case are identical to those in the case of Aditya Gupta and Printed from counselvise.com ITA No.1546/Del/2025 Page 12 of 13 Venizzia Golf City (supra). Thus, for the purposes of consistency and in respectful compliance to the judicial precedents discussed hereinabove, we are of the considered view that the PCIT, Delhi, did not have any authority under section 263 qua an order for which approval under section 153D of JCIT was available. Consequently, we set-aside and quash the impugned order under section 263 for AY 2013-14 contested by the assessee through ITA No.1546/Del/2025. The additional ground of appeal raised by the assessee is allowed. 10. As the additional grounds raised by the assessee qua legal grounds has been allowed, all other grounds raised by the assessee have become academic in nature and bereft of any meritorious adjudication. 11. As the facts for AY 2014-15 contested vide ITA NO.1548/Del/2025 are identical to ITA No.1546/Del/2025, the decision taken in ItA No. 1546/Del/2025 shall apply mutatis mutandis. Accordingly, we set-aside and quash the impugned order under section 263 for AY 2014-15 contested by the assessee through ITA No.1548/Del/2025 also. 12. In the result, both the appeals of the assessee are allowed. Order pronounced in the open court on 27th February, 2026. Sd/- Sd/- [YOGESH KUMAR U.S.] [AMITABH SHUKLA] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 27.02.2026 Printed from counselvise.com ITA No.1546/Del/2025 Page 13 of 13 f{x~{tÜ f{x~{tÜ f{x~{tÜ f{x~{tÜ Copy forwarded to: 1. Appellant 2. Respondent 3. PCIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi, Printed from counselvise.com "