आयकर अपीलीय अिधकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad Before Shri Manjunatha G., Accountant Member and Shri Ravish Sood, Judicial Member आ.अपी.सं /ITA No.996/Hyd/2024 (िनधा१रण वष१/Assessment Year: 2017-18)

Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal.

Warangal.

PAN: AAOPT4519M (Appellant) (Respondent) िनधा१ौरती (cid:554)ारा/Assessee by: Shri K.A. Sai Prasad, CA राज(cid:830) व (cid:554)ारा/Revenue by: Mrs. U. Mini Chandran, CIT-DR सुनवाई की तारीख/Date of Hearing: 18/11/2025 घोषणा की तारीख/Date of 10/12/2025 Pronouncement:

आदेश / ORDER PER. RAVISH SOOD, J.M:

The present appeal filed by the revenue is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 06/08/2024 which in turn arises from the order passed by the Assessing Officer under section 147 r.w.s 144B of the Income-Tax Act, 1961 (for short, “the Act”), dated 26/05/2023 for the Assessment Year 2017-18. The revenue has assailed the impugned order on the following grounds of appeal before us:

1. “The Id CIT(A) erred both on law and on facts in giving relief to the assessee.

2. The Id CIT(A) ought to have