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2025 Supreme(Online)(ITAT) 8150

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
T.R. Senthil Kumar, JM, Makarand V. Mahadeokar, AM
Olympic Décor LLP – Appellant
Versus
Pr.Commissioner of Income Tax-3 – Respondent


Advocates:
For the Appellants/Petitioners:Shri Tushar Hemani, Sr.Advocate, Parimalsinh B. Parmar, ARs
For the Respondents: Shri Rignesh Das, CIT-DR

Table of Content
1. establishment of initial assessment process and pcit's later objections. (Para 2 , 3 , 4 , 5)
2. court's examination of pcit's grounds for invoking revision and evaluation of the legitimacy of depreciation claims. (Para 14 , 15 , 16 , 17 , 18 , 19)
3. final ruling reaffirming the assessment order as valid based on factual inquiries. (Para 25 , 26)

ORDER

PER MAKARAND V.MAHADEOKAR, AM:

This appeal is preferred by the assessee against the order passed under section 263 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Principal Commissioner of Income Tax-3, Ahmedabad [hereinafter referred to as “PCIT”] dated 22.02.2024 for the Assessment Year 2018–19, wherein the learned PCIT set aside the assessment order passed under section 143(3) of the Act dated 30.04.2021 by the Assessing Officer and directed de novo assessment, holding the said order to be erroneous in so far as it is prejudicial to the interest of the Revenue.

Facts of the Case

2. The assessee, M/s. Olympic Décor LLP (formerly Sara Suppliers LLP), filed its return of income for A.Y. 2018–19, which was selected for scrutiny. The assessment was completed under section 143(3) vide order dated

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