IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND Ms. ASTHA CHANDRA, JUDICIAL MEMBER Assessment year : 2014-15 Assessment year : 2014-15 Assessment year : 2014-15 Assessment year : 2014-15 Assessment year : 2014-15 Assessment year : 2014-15 Assessee by : Shri Sanket Joshi Department by : Shri Amol Khairnar, CIT-DR Date of hearing : 08-01-2026 Date of pronouncement : 16-01-2026

O R D E R

PER R.K. PANDA, V.P:

This appeal filed by the assessee is directed against the order dated

18.03.2020 passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Ld. PCIT-1, Nashik relating to assessment year 2014-15.

2. Although a number of grounds have been raised by the assessee, however, these all relate to the validity of 263 proceedings initiated by the Ld. PCIT.

3. Facts of the case, in brief, are that the assesse is a company engaged in the business of running hotels at Nashik and Goa. It filed its return of income for the assessment year 2014-15 on 04.02.2016 declaring total loss of Rs.91,83,541/-. The case of the assessee was reopened u/s 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) and th