IN THE INCOME TAX APPELLATE TRIBUNAL “B’’BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No.854/Bang/2025 Assessment Year : 2020-21 Muthyala Suryababu Pr. CIT, Bangalore – 1 M/s. Guruswamy and Associates Income Tax Office, BMTC Building No.311, 1^st Floor, 10^th Main, 3^rd Block Koramangala, Bangalore - 560095 Vs.

Jayanagar, Bangalore - 560011 PAN NO :AGAPS5455P APPELLANT RESPONDENT Assessee by : Shri H. Guruswamy, ITP Department by : Shri Murali Mohan, CIT DR Date of Hearing : 19.06.2025 Date of Pronouncement : 15.09.2025

O R D E R

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the Order of the ld. PCIT, Bengaluru–1 dated 28.03.2025 vide DIN & Order No. ITBA/REV/F/REV5/2024-25/1075190463(1) passed u/s. 263 of the Income Tax Act, 1961 (in short “the Act”) for the assessment year 2020-21.

2. The assessee has raised the following grounds of appeal: “1. The impugned Order passed u/s 263 of the Act 28-03-2025 by PCIT Bangalore - 1 is opposed to Law and facts of the case.

2. The Ld. PCIT Bangalore -1 has erred in assuming the Jurisdiction u/s 263 of the Act on the basis of the clause (a)