, , आयकर अपीलीय अिधकरण इंदौर (cid:586)ायपीठ इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M. JOSHI, JUDICIAL MEMBER ITA No.713/Ind/2024 Assessment Year: 2018-19 Malwa Oxygen & Industrial ITO, NFAC, Gases Private Ltd., Delhi Sector -C, /

बनाम Industrial Area, Vs.

Ratlam (Assessee/Appellant) (Revenue/Respondent)

PAN: AACCM4635N Assessee by Shri Pankaj Shah & Soumya Bomb, ARs Revenue by Shri Ashish Porwal, Sr. DR Date of Hearing 24.09.2025 Date of Pronouncement 07.10.2025 आदेश / O R D E R Per B.M. Biyani, A.M.:

Feeling aggrieved by order of first appeal dated 29.07.2024 passed by learned Commissioner of Income-Tax (Appeals)-NFAC, Delhi [“CIT(A)”] which in turn arises out of assessment-order dated 17.04.2021 passed by learned National e-assessment Centre [“AO”] u/s 143(3) r.w.s. 144B of Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2018-19, the assessee has filed this appeal on following grounds:

“1. On the facts and circumstances ofthe case and in law the learned CIT(A) erred in making disallowance of deduction under Section 35(2AB) of the Act amounting to Rs. 78,72,495. The Appellant prays that the