आदेश/ORDER

PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal has been filed by the assessee against the order passed by the Principal Commissioner of Income Tax, Mumbai–4 [hereinafter referred to as “PCIT”], dated 26.03.2025, under section 263 of the Income-tax Act, 1961[hereinafter referred to as “the Act”], whereby the assessment order dated 28.02.2023 passed by the Assessing Officer under section 147 read with section 144B of the Act for A.Y. 2017–18 was held to be erroneous and prejudicial to the interest of the Revenue and was set aside with directions.

Facts of the Case

2. The assessee is a private limited company. It filed its return of income for A.Y. 2017–18 on 23.03.2018 under section 139(4) declaring total income of Rs. 19,370/-. The return was processed under section 143(1) and thereafter a regular assessment was completed under section 143(3) on 22.10.2019 by Central Circle– 2(2), Mumbai, determining income at Rs. 19,370/-.

3. Subsequently, reassessment proceedings were initiated and notice under section 148 was issued on 29.07.2022. In response, the assessee filed return of income on 08.11.2022, again declaring income of Rs. 19,370/-. Notice under section 143(2) was issued o