IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘B’: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER ITA No.2644/Del/2025 [Assessment Year: 2016-17 ]

Manohar & Filaments Pvt. `Vs. PCIT, (Central)-3, Delhi Ltd, B-59, G. T. Karnal Road, Industrial, Area, New Delhi PAN No.AAACM1116E Appellant Respondent Appellant by Sh. Amit Goel, CA Sh. Pranav Yadav, Advocate Respondent by Ms. Pooja Swaroop, CIT DR Date of Hearing 04.12.2025 Date of 31.12.2025 Pronouncement

ORDER

PER C.N. PRASAD, JM, This appeal is filed by the assessee against the order of the Ld.PCIT (Central)-3, Delhi vide order dated 11.03.2025 for the A.Y. 2016-17 passed u/s.263 of the Act.

2. The assessee has raised following grounds of appeal :-

“1. On the facts and circumstances of case and in

law, the Id. PCIT, Central 3, New Delhi erred in

initiating proceedings under section 263 of Income Tax

Act, 1961 (Act) by wrongly assuming jurisdiction under section 263 of the Act and hence, the order passed by the Ld. CIT under section 263 of Act is bad in law, without jurisdiction and barred by limitation.

2. On the facts and circumstances of case and in law, the Id. PCIT erred in setting asid