IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.4178/MUM/2025 (Assessment Year:2011-2012)

Mayur Govindbhai Patel C-3002, HDIL Metropolis Tower, J. P. Road, Andheri West, Mumbai - 400053.

Maharashtra [PAN: AAGPP3288B] …………. Appellant Vs Income Tax Officer Ward 24(2)(1), Mumbai Room No.608, 6^th Floor, Piramal Chambers, Lalbaug, Mumbai - 400012. Maharashtra. …………. Respondent Appearance For the Appellant/Assessee : Shri Dhaval Shah For the Respondent/Department : Shri Umashankar Prasad Date Conclusion of hearing : 30.10.2025 Pronouncement of order : 23.12.2025

O R D E R

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Per Rahul Chaudhary, Judicial Member:

1. By way of the present appeal the Assessee has challenged the order, dated 15/03/2021, passed by the Learned Principal Commissioner of Income Tax, Mumbai - 20 [hereinafter referred to as ‘the PCIT’ under Section 263 of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] whereby the Assessment Order, dated 27/12/2017, passed under Section 143(3) read with Section 147 of the Act was set aside as being erroneous in so far as prejudicial to the interest of Revenue.

2. The Assessee has r