vk;dj vihyh; vf/kdj.k] t;iqj U;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR MkW-a ,e- ,y- ehuk] ys[kk lnL; ,oa MkW-a ,l- lhrky{eh] U;kf;d lnL; ds le{k BEFORE: DR. MITHA LAL MEENA, AM & DR. S. SEETHALAKSHMI, JM vk;dj vihy la-@

ITA. No. 600/JPR/2025 fu/kZkj.k o"kZ@

Assessment Years : 2021-22 M/s Zari Silk (India) Pvt. Ltd. cuke Principal Commissioner of

10/11, Narain Singh Circle, Vs. Income Tax Jaipur (Central), Jaipur. Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAACZ2642J vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@

ITA. No. 599/JPR/2025 fu/kZkj.k o"kZ@

Assessment Years : 2021-22 Sh. Arun Palawat cuke Principal Commissioner of C-55-A, Priyadarshni Marg, Tilak Vs. Income Tax Jaipur (Central(, Nagar, Raja Park Colony, Jaipur. Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAQPP7460D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@

Assessee by : Shri S.R. Sharma, C.A. &

Shri R.K. Bhatra, C.A.

jktLo dh vksj ls Revenue by : Shri Rajesh Ojha, CIT-DR a lquokbZ dh rkjh[k@

Date of Hearing : 16/07/2025 mn?kks"k.kk dh rkjh[k@Date of Pronouncement : 15/09/2025 vkns'k@ ORDER PER DR. S. SEETHALAKSHMI, J.M.

Both these appeals filed by the two assessees arise from two separate orders of ld. PCIT(Central), Jaipur dated 23.03.2025 passed under section 263 of the I.T. Act, 1961, for the assessment year 2021-22.

2. The assessees have raised the following grounds of appeal :-

ITA No. 600/JPR/2025 (ASSESSEE COMPANY)

“1. That on the facts and in the circumstances of the case the ld. PCIT (Central), Jaipur is wrong, unjust and has erred in law in not accepting submission of the appellant company that the notice dt 21.11.2024 issued by her to the appellant company for initiating revision proceedings u/s 263 of the IT Act, 1961 is wrong and bad in law in as much as power of the ld. Pr. CIT under this section do not extend to the assessments made in search cases by AO after obtaining mandatory approval of Addl. CIT u/s 148B of the IT Act, 1961.

2. That without prejudice to the ground No. (1) above on the facts and in the circumstances of the case the ld. Pr. CIT is wrong, unjust and has erred in law in initiating and passing impugned order u/s 263 of the IT Act, 1961 in as much as issue involved in the revision proceeding was thoroughly considered and examined by the ld. AO by application of mind and so impugned order passed by her is mere change of opinion.

3. That without prejudice to the ground No. (1) and (2) above on the facts and in the circumstances of the case the ld. Pr. CIT is wrong, unjust and has erred in law in setting aside the assessment order dated 30.12.2022 passed by the ld. AO u/s 143(3) of the IT Act, 1961 by holding it to be erroneous in so far as it is prejudicial to the interest of revenue under clause (a) of expl-2 to sec. 263 allegedly on the ground that addition of Rs. 33,90,001/- made by the AO as normal income under the head income from other sources instead assessing it u/s 69A/ 69C r/w sec. 115 BBE of the IT Act, 1961.

4. The appellant craves permission to add to or amend to any of grounds of appeal or to withdraw any of them.”

ITA No. 599/JP/2025 (ASSESSEE)

“1. That on the facts and in the circumstances of the case the ld. PCIT (Central), Jaipur is wrong, unjust and has erred in law in not accepting submission of the appellant that the notice dt 22.11.2024 issued by her to the appellant company for initiating revision proceedings u/s 263 of the IT Act, 1961 is wrong and bad in law in as much as power of the ld. Pr. CIT under this section do not extend to the assessments made in search cases by AO after obtaining mandatory approval of Addl. CIT u/s 148B of the IT Act, 1961.

2.That without prejudice to the ground No. (1) above on the facts and in the circumstances of the case the ld. Pr. CIT is wrong, unjust and has erred in law in initiating and passing impugned order u/s 263 of the IT Act, 1961 in as much as issue involved in the revision proceeding was thoroughly considere