आयकर अपील(cid:547)य अ(cid:876)धकरण Ûयायपीठ रायपुर म(cid:581)।

IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI ARUN KHODPIA, ACCOUNTANT MEMBER Sl. Appeal No. Name of Appellant Name of Respondent Asst. Year No.

1. 479/RPR/2024 Sanket Jhabak The Pr. Commissioner 2013-14 Jhabak Bada, Kamasipara, of Income Tax-1, Raipur (C.G.)-492 001 Raipur (C.G.)

PAN : AEQPJ7137M Sanjog Jhabak The Pr. Commissioner Jhabak Bada, of Income Tax-1, 2. 233/RPR/2024 Kamasipara Raipur (C.G.) 2013-14 Raipur (C.G.)-492 001 PAN: ADNPJ2775K Sanjog Jhabak The Pr. Commissioner L/h. Late Shri Gautam of Income Tax-1, Chand Jhabak Raipur (C.G.) 2013-14

3. 234/RPR/2024 Jhabak Bada, Kamasipara Raipur (C.G.)-492 001 PAN: ACIPJ2421J Smt. Sushila Devi Jhabak The Pr. Commissioner Jhabak Bada, of Income Tax-1, Kamasipara Raipur (C.G.) 2013-14

4. 235/RPR/2024 Raipur (C.G.)-492 001 PAN: AESPJ9825L Smt. Tilottma Jhabak The Pr. Commissioner Jhabak Bada, of Income Tax-1, 5. 236/RPR/2024 Kamasipara Raipur (C.G.) 2013-14 Raipur (C.G.)-492 001 PAN: ACTPJ5814G Assessee by : Shri Nikhilesh Begani, Advocate Revenue by : Shri S.L Anuragi, CIT-DR सुनवाई क(cid:551) तार(cid:547)ख / Date of Hearing : 29.01.2025 घोषणा क(cid:551) तार(cid:547)ख / Date of Pronouncement : 19.02.2025 आदेश / ORDER PER BENCH:

The captioned appeals filed by the assessee’s are directed against the respective orders passed by the Pr. Commissioner of Income- Tax-1, Raipur, (for short, “Pr. CIT”) for A.Y.2013-14, which in turn arises from the respective orders passed by the A.O’s under Sec.147 r.w.s. 144B of the Income-tax Act, 1961 (in short ‘the Act’), as under:

2. Shri Nikhilesh Begani, Ld. Authorized Representative (for short ‘AR’)

for the assessee, at the threshold of hearing, submitted that as the issues leading to the controversy involved in the captioned appeals finds its genesis in common facts involved in the said respective appeals, therefore, the same can be taken up and disposed off vide a consolidated order. Elaborating further, the Ld. AR submitted that the appeal filed in ITA No.479/RPR/2024 in the case of Sanket Jhabak may be taken as the lead matter.

3. Shri S.L Anuragi, Ld. Departmental Representative (for short ‘CIT- DR”) did not raise any objection to the aforesaid request of the assessee’s counsel.

4. We shall now take up the appeal in ITA No.479/RPR/2024 for A.Y.2013-14 as the lead matter, and the order passed therein shall mutatis- mutandis apply for the purpose of disposing off the remaining appeals. The assessee has assailed the impugned order passed by the Pr. CIT u/s. 263 of the Act, dated 18.10.2024 on the following grounds of appeal before us:

“GROUND No.I.

1. That the Re-assessment Order framed u/s.147 r.w.s. 144B of the Income Tax Act, 1961 ("the Act') on 30.05.2023 by the Learned Assessing Officer, National Faceless Assessment Centre, Delhi ("the Ld.AO'), the reopening notice issued u/s.148 on 26.07.2022 & the Order passed u/s.148A(d) on 26.07.2022 is bad in law, highly illegal, without jurisdiction, barred by limitation & void ab initio since, the reopening notice u/s.148 and the subsequent proceedings are not in conformity with the pre-requisite conditions stipulated under the provisions of section 148/148A/147 of the Act when examined on the touchstone of the law propounded by the Hon'ble Supreme Court, consequentially, the impugned Revision Order passed by the Learned Pr. Commissioner of Income Tax-1, Raipur ("the Ld.PCIT') u/s.263 setting aside the Assessment Order passed u/s.147 r.w.s. 144B on 30.05.2023 is illegal, bad in law, legally unsustainable and without jurisdiction hence, it is earnestly prayed that the Revision Order passed u/s.263 on 18.10.2024 may please be quashed and cancelled in limine.

GROUND No. II

2. That the Revision Order passed by the Ld.PCIT u/s.263 of the Act cancelling/modifying the reassessment order is highly unjustified, bad in law, against the principles of natural justice, clearly exceeding the revisio