IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year: 2020-21 Assessment Year: 2020-21 Assessment Year: 2020-21 Assessment Year: 2020-21 Assessment Year: 2020-21 Assessment Year: 2020-21 Assessment Year: 2020-21 Assessment Year: 2020-21 Assessee by : Shri Ramaraju, Advocate Revenue by : Shri Subramanian, JCIT Date of hearing : 13.01.2026 Date of Pronouncement : 20.01.2026

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This appeal is directed against the order passed by the learned Principal Commissioner of Income-tax–2, Bengaluru under section 263 of the Income-tax Act, 1961 dated 31.03.2025, whereby the assessment order passed under section 143(3) read with section 144B of the Act dated 07.09.2022 was set aside for fresh assessment.

2. The assessee has raised the following grounds of appeal:

1. The order passed by the learned Principal Commissioner of Income-Tax-2, is bad in law and contrary to the settled principles of law on the facts and circumstances of the case.

2. The Appellant denies itself liable to be assessed in excess of returned income as assessed and accepted by the lear