IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER आयकर अपील स.ं / ITA No.953/PUN/2024 Assessment Year : 2018-19 Manjusha Anil Lodha, PCIT, Nashik-1 L/H of Late Anil Bansilal Lodha, Vs.

Mangal Bhavan, Opp Swami Vivekanand School, Panchvati, Nashik – 422 003 Maharashtra PAN : AAGPL1981M Appellant Respondent Appellant by : Shri Pramod S. Shingte Respondent by : Shri Amol Khairnar Date of hearing : 21.07.2025 Date of pronouncement : 10.10.2025 आदेश / ORDER PER DR. MANISH BORAD, ACCOUNTANT MEMBER : This appeal at the instance of Legal Heir of Assessee is against the order dated 21.03.2024 of the Principal Commissioner of Income tax, Nashik – 1 passed u/s.263 of the Income Tax Act, 1961 for A.Y.2018-19 emanating from Assessment Order dated 28.04.2021 passed u/s.143(3)

r.w.s.144B of the Act.

2. Assessee has raised following grounds of appeal :

“1. On the basis of the facts and circumstances of the case, the order passed u/s. 263 by the Principal Commissioner of Income-tax, Nashik may please be quashed.

2. On the basis of the facts and circumstances of the case and as per law, the Principal Commissioner o