IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI ARUN KHODPIA, ACCOUNTANT MEMBER (Assessment Year: 2020-21)

Hampi Expressways Pvt. Ltd., Principal Commissioner of

2^nd Floor, Eliphinstone Building, 10 Income Tax -1, Veer Nariman Road, Fort, Vs. Room No.330, 3^rd Floor, Aayakar Mumbai-400001 Bhavan, Maharshi Karve Road, Mumbai (Appellant) : (Respondent)

PAN NO. AADCH 6031L Appellant by : Shri Nitesh Joshi, Advocate, Shri Amey Wagle, CA Respondent by : Shri Ritesh Misra, CIT- DR (Appellant) (Respondent)

Date of Hearing : 25.09.2025 Date of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey, Vice President:

Present appeal, at the instance of the assessee, assails the order dated

31.03.2025 passed under Section (u/s.) 263 of the Income Tax Act, 1961 (hereinafter called the ‘Act’) by learned Principal Commissioner of Income Tax (PCIT), Mumbai pertaining to Assessment Year (AY) 2020-21.

2. At the outset, learned counsel appearing for the assessee submitted that the appeal can be decided on the limited issue raised in Ground No.2, which reads as under:

“2. The learned Commissioner of Income Tax erred in passing an order under section 263 wi