IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.2192/MUM/2024 (Assessment Year : 2017–18)

M/s. G M Builders, 115, Veena Beena Shipping Center, Turner Road, Bandra West, Mumbai - 400050 PAN – AAAFG1872G ……………. Appellant v/s PCIT, Mumbai Old – ACIT, Circle – 22(1), Piramal Chamber Parel, ……………. Respondent Mumbai - 400050, Maharashtra Assessee by : Share Hari Raheja Revenue by : Shri Himanshu Joshi - Sr. DR, Dr. Kishore Dhule-CIT DR Date of Hearing – 24/01/2025 Date of Order – 12/03/2025

O R D E R

PER SANDEEP SINGH KARHAIL, J.M.

The assessee has filed the present appeal challenging the impugned order dated 29/03/2024, passed under section 263 of the Income Tax Act, 1961 (“the Act”) by the learned Principal Commissioner of Income Tax, Mumbai-20, [“learned PCIT”], for the assessment year 2017-18.

2. In this appeal, the assessee has raised the following grounds: –

“1. On the facts and the circumstances of the case and in laws, the CIT was not justified at initiating proceedings u/s 263 of the Income Tax Act, 1961.

The appellant submits that then proceedings initiated u/s 263 of the Income Ta