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 the facts and the circumstances of the case of the appellant, the order u/s 263 of the act passed by Ld. PCIT is bad in law and deserves to be quashed.

2. In law and in the facts and the circumstances of the case of the appellant, the Ld PCIT has erred in holding that assessment order passed u/s 143(3) r.w.s. 144C on 29/09/2022 is erroneous and prejudicial to interest of revenue and set aside such order u/s 263 of the Act.

3. In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has erred in observing that AO failed to consider the necessity of revisiting the method of disallowance under Rule 8Dread with Section 14A.

3.1 In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has failed to appreciate that the appellant has submitted all relevant details during assessment proceeding which are on record of Ld. Assessing Officer and he duly applied his mind and not made further addition u/s 14A. Thus, the assessment order was not erroneous and prejudicial to interest of revenue.

4. In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has erred in concluding that appellant has received accommodation entry from Shri Dilip C. Patel in relation of Robin Goenka (Sankalp Group).

4.1 In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has erred in stating that the assessment order is erroneous merely on the basis of information received from insight portal.

4.2 In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has erred in stating that the assessment order is erroneous without making any independent inquiry to satisfy himself that assessment order is erroneous and prejudicial to interest of revenue.

4.3 In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has erred in stating that the assessment order is erroneous without providing material to appellant based on which he alleged that appellant has received accommodation entry.

3. Facts of the case are that the assessment was completed under section 143(3) r.w.s. 144B of the Act determining total income at Rs. 14,82,47,32,193/-.According to the revision order, on examination of assessment records, it was observed by the ld.Pr.CIT that the AO failed to verify certain material issues while completing the assessment.The assessee earned exempt income of Rs.274,21,78,924/-during the year but made a suo motu disallowance of only Rs.1,82,21,8671/-under section 14A of the Act. It was noticed that the assessee had Strategic Investments of Rs.11813.76 cr., on which no proportionate disallowance was computed as per Rule 8D. The Pr.CIT opined that correct disallowance should have been Rs.118.13 cr., resulting in a sho