आयकर अपील(cid:547)य अ(cid:876)धकरण, कोलकाता पीठ, कोलकाता

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA Before Shri Rajesh Kumar, Accountant Member and Shri Pradip Kumar Choubey, Judicial Member Assessment Year: 2021-22 Arun Engineering Udyog Pvt. Ltd……………………………….……….……Appellant

151/A, Cotton Street, Burrabazar, KOl - 700007.

[PAN: AALCA8127A]

vs.

PCIT(Central)-2, Kolkata…………………………………….....……...…..…..Respondent Appearances by:

Shri Miraj D Shah, AR, appeared on behalf of the appellant.

Shri Raja Sengupta, CIT- DR, appeared on behalf of the Respondent.

Date of concluding the hearing : September 04, 2025 Date of pronouncing the order : September 11, 2025 ORDER Per Pradip Kumar Choubey, Judicial Member:

The present appeal has been preferred by the assessee against the order dated 14.02.2025 of the Principal CIT(Central), Kolkata [hereinafter referred to as the “ld. PCIT”] exercising his revision jurisdiction u/s 263 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”].

2. The brief facts of the case are that the assessee filed its return of income u/s 139 of the Act showing total income at Nil. A search and seizure operation u/s 132 of the Act was conducted in the cases of