IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 579/SRT/2025 (Assessment Year: 2021-22)

Sunil Kumar Baheti, Principal Commissioner of Vs.

1009-10, New Textile Market, Income-tax (Central), Ring Road, Surat-395002 Surat [PAN : AIYPB 2308 J]

(Appellant) .. (Respondent Appellant represented by : Shri Ramesh Malpani, CA Respondent represented by: Shri Mukesh Jain, CIT (DR)

Date of Hearing 22.01.2026 Date of Pronouncement 17.02.2026

O R D E R

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

This appeal filed by the assessee is directed against the order passed by the learned Principal Commissioner of Income-Tax (Central), Surat [herein-after referred to as “PCIT”] dated 31.03.2025, in exercise of revisionary powers under Section 263 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment Year (AY) 2021-22.

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

“1. That on the facts and in the circumstances of the case as well as in law, the order passed by ld. Principal Commissioner of Income Tax (Central), Surat (PCIT) u/s. 263 of the I. T. Act, 1961 ("the Act") is wrong an