IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER (Assessment Year: 2015-16)

Bipinkumar Rambhai Patel, Vs. Principal Commissioner of B/25, Ranchod Colony, Income-tax-1, Maninagar, Ahmedabad-380008 Ahmedabad-1 [PAN :AQAPP 5046 M]

(Appellant) .. (Respondent Appellant represented by : Shri Mehul K. Patel, Advocate Respondent represented by: Shri R.P. Rastogi, CIT-DR Date of Hearing 26.11.2025 Date of Pronouncement 30.01.2026

O R D E R

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-

This appeal has been filed by the assessee against the order passed by the Ld. Principal Commissioner of Income-tax, Ahmedabad-1 (hereinafter referred to as "PCIT" for short), dated 16.03.2024, in exercise of his revisionary powers under Section 263 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment Year (AY) 2015-16.

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

“1. The learned PCIT has erred in law and on facts in passing the order u/s.263 of the Act while considering the assessment order u/s.147 r.w.s 144 r.w.s 1448 of the Act passed by the FAO on 24/03/2022 for the year in questi