ORDER

Per, Dr. A. L. Saini, AM:

By way of this appeal, the assessee has challenged the correctness of the order dated 22.10.2024 passed by the Learned Principal Commissioner of Income-tax (in short “Ld PCIT”) under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for the assessment year 2020-21. Grievances raised by the assessee, which, being interconnected, will be taken up together, are as follows:

2. Grounds of appeal raised by the assessee are as follows:

“1. The Ld. PCIT erred in law as well as on fact in assuming jurisdiction u/s.263 of the Act.

2. The Ld. PCIT erred in law as well as on fact in holding that order passed u/s 143(3) by Ld.AO is erroneous and prejudicial to the interest of revenue.”

3. The facts of the case which can be stated quite shortly are as follows: The assessee has filed original return of income for assessment year under consideration, on 19/01/2021, declaring total income of Rs. 16,61,010/-. The said return of income was revised on 03/02/2021, declaring total income at Rs. 15,85,390/-. Thereafter, the case of the assessee for the assessment year under consideration was selected for complete scrutiny assessment. Accordingly, t