आदेश/ORDER

PER AMITABH SHUKLA, A.M :

This appeal is filed by the assessee against the order bearing DIN & Order No.ITBA/REV/F/REV5/2024-25/1070000889(1) dated 28.10.2024 of the Leaned Principal Commissioner of Income Tax,(herein after “PCIT’), Chennai u/s 263 for the assessment year 2009-10.

2.0 The only issue contested by the appellant assessee through its six grounds of appeal, is regarding the invocation of revisionary jurisdiction u/s 263 of the Act by the Ld.PCIT-4. It is the case of the assessee that the impugned order of the Ld.AO passed u/s 154 of Act dated 02.06.2022 does not qualify as an order which is erroneous in so far as it is prejudicial to the interest of Revenue and therefore the assumption of jurisdiction of the PCIT was wrong.

3.0 It has been noted that there is a delay of 51 days in the case, in filing of this appeal before the tribunal. In its affidavit the assesse has pleaded that the assesse was exposed to the order u/s 263 dated 28.10.2024 which was linked to passing of order u/s. 154. It is the case of the assessee that around the time there was a change in the management team of the assessee as result of which some additional time was consumed for internal d