IN THE INCOME-TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER &

SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No.3474/MUM/2025 (A.Y. 2019-20)

Ambuja Cements Limited v/s. Principal Commissioner of Adani Corporate House, बनाम Income Tax, Mumbai – 3, Shantigram Near Vaishnodevi Room No. 612, 6th Floor, Circle, SG Highway, Khodiyar Aayakar Bhavan, Maharishi Gandhi Nagar, Gujarat – Karve Road, Mumbai –

382421, Gujarat 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAACG0569P Appellant/अपीलार्थी .. Respondent/प्रतिवादी

Appellant by : Shri Sourabh Soparkar, AR (virtually appear)

Respondent by : Shri Rajesh Kumar Yadav, (CIT-DR)

Date of Hearing 08.12.2025 Date of Pronouncement 05.02.2026 आदेश / O R D E R PER PRABHASH SHANKAR [A.M.] :-

The present appeal is filed by the assessee against the Revision order passed by the Principal Commissioner of Income-tax, PCIT, Mumbai-3 [hereinafter referred to as “PCIT”] u/s 263 of the Act, pertaining to the assessment order passed u/s. 143(3) of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 29.09.2022 for the Assessment Year [A.Y.] 2019-20.

2. The grounds of appeal are as under:

1. In law and in