IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER (Hybrid Hearing)

DCIT, vs. Asodariya Gordhanbhai Circle- 1(3), Ranchhodbhai (HUF), Surat 8, Raghuvir Bungalow, City Light Road, Surat, Gujarat (cid:830)थायीलेखासं /.जीआइआरसं /.PAN/GIR No: AACHA7033D (Appellant) (Respondent)

Appellant by Shri Mukesh Jain, CIT-DR with Shri Kevin Langaliya, CA Respondent by Shri Manish J. Shah, Advocate Date of Hearing 07/11/2025 Date of Pronouncement 29/12/2025 आदेश / O R D E R PER DINESH MOHAN SINHA, JM:

This appeal by the revenue emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act’) by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, [in short, ‘CIT(A)’]

dated 03.07.2023 for assessment year (AY) 2017–18.

2. The grounds of appeal raised by the revenue are as follows:

“1. On the facts and circumstances of the case and in law, the ld. CIT(A) has erred in directing the AO to allow the assessee's claim for deduction of Rs.4,77,37,017/- u/s

54F of the Income-tax Act.

2. On the facts and in the circumstances of the case and in law, t