आदेश/ORDER

PER PRABHASH SHANKAR [A.M.] :-

The present appeal is filed by the assessee against the Revision order u/s 263 of the Act passed by the Principal Commissioner of Income-tax, PCIT, Mumbai-8 [hereinafter referred to as “PCIT”] pertaining to assessment order made u/s. 147 r.w.s. 144B of the Income- tax Act, 1961 [hereinafter referred to as “Act”] dated 28.02.2023 for the Assessment Year [A.Y.] 2018-19.

2. The grounds of appeal are as under:-

1. On the facts and circumstances of the case and in law, the Learned Principal Commissioner of Income Tax, [hereinafter referred to as “Ld. PCIT”] erred in invoking jurisdiction under Section 263 of the Income Tax Act, 1961 (“the Act”) and passing the impugned order dated 01/02/2025, which is bad in law and liable to be quashed for various reasons including that the very assessment which has been revised is bad in law.

2. On the facts and circumstances of the case and in law, the assessment order passed by the (“Ld. AO”) under section 147 read with section 144B of the Act dated 28/02/2023 is erroneous and prejudicial to the interests of the revenue, without satisfying any of the mandatory conditions laid down under section 263 of the Act.

3.