IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आयकरअपीलसं./ITA No.165/RJT/2024 Assessment Year: (2016-17)

(HybridHearing)

M/s. Sober Ceramics Vs. The ITO, 8 – A, National Highway, At. Ward – 4, Nava Jambudiya, Morbi - 363642 Morbi – 363641 Gujarat èथायीलेखासं./जीआइआरसं./PAN/GIR No.: AALFS3898R (Appellant) (Respondent)

Appellant by : Shri Mehul Ranpura, Ld. A.R.

Respondent by : Shri Abhimanyu Singh Yadav, Ld. Sr. DR Date of Hearing : 12/12/2024 Date of Pronouncement : 28/02//2025 आदेश / O R D E R PER DR. A. L. SAINI, AM:

Captionedappeal filed by the assessee, pertaining to Assessment Year (AY) 2016-17, is directed against the order passed by the Learned Commissioner of Income Tax(Appeals), vide order dated 18.01.2024,which in turn arises, out of an assessment order passed by Assessing Officer (in short ‘the AO”)under section143(3) of the Income Tax Act, 1961 ( herein after referred to as “the Act”), order dated 17.12.2018.

2. Grounds of appeal raised by the assessee, are as follows:

1. The grounds of appeal mentioned hereunder are without prejudice to one another.

2. The Id. Commissioner o