IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER&

SHRI ARUN KHODPIA, ACCOUNTANT MEMBER ITA No. 2639/MUM/2025 (AY: 2012-13)

(Physical hearing)

Prakash Cotton Mills Pvt Ltd DCIT, Circle 8(2)(1), Mumbai

1^st Floor, Apsara Cinema Building, Vs Room No.624, 6^th Floor, Aayakar Bhadkamkar Marg, Grant Road (E) Bhavan, M.K. Road, Mumbai Mumbai-400 007 PAN : AAACP0550H Appellant / Revenue Respondent / Assessee Assessee by Shri J.D. Mistry, Senior Advocate with Shri Tanzil Padvekar, Advocate Revenue by Shri R.A. Dhyani, CIT DR Date of Institution 17.04.2025 Date of hearing 18.09.2025 Date of pronouncement 26.09.2025 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER;

1. This appeal by assessee is directed against the order of ld. CIT(A) / NFAC dated 05.03.2025for A.Y. 2012-13. The assessee has raised the following grounds:_

“I. Re-opening under Section 147 and Notice issued under Section 148 of the Act, 1961 bad in law as not meeting jurisdictional requirements:

1. On the facts and in law, proceedings initiated under Section 147 and Notice issued under Section 148 of the Income Tax Act, 1961 (in short referred as Act of 1961) ar