IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment Year : 2020-21 M/s. Site Concepts Pvt.

Ltd., 27/1-2, 1^st Floor, The Income Tax Elegant Queensbury, Officer, Richmond Rd, Ward – 6(1)(1), Victoria Layout, Bangalore.

Vs.

Bengaluru – 560 047.

PAN: AAHCS1477M APPELLANT RESPONDENT Assessee by : Shri K.B. Muralidharan, CA Revenue by : Shri Pradeep S, Addl. CIT-DR Date of Hearing : 15-07-2025 Date of Pronouncement : 13-10-2025

ORDER

PER SOUNDARARAJAN K., JUDICIAL MEMBER This is an appeal filed by the assessee challenging the order of the NFAC, Delhi dated 10/09/2024 in respect of the A.Y. 2020-21 and raised the following grounds:

“1. The impugned order passed by Honorable Commissioner of Income Tax (appeals), National Faceless Appeal Centre [CIT(A)jis not justified in law and against facts and circumstances of the case.

2. The CIT(A) had failed to appreciate that order of the Assessing officer (AO) is bad in law as he had no reasons to assess an income different from what had been offered by the appellant.

3. The CIT(A) had failed to appreciate thatAO had failed to give proper opportun