IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘E’: NEW DELHI BEFORE SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTNAT MEMBER ITA Nos.3419 to 3421/DEL/2025 [Assessment Years: 2014-15, 2015-16 & 2016-17]

R.G. INTERNATIONAL Income Tax Officer, PRIVATE LIMITED, 3 K M Ward-1, Karnal MILE STONE KARNAL Vs KAITHAL ROAD , NISSING KARNAL 132024 , Haryana PAN-AAGCR0129J Appellant Respondent Appellant/Assessee by Shri Vikrant Kackria, Adv.

Respondent/Revenue by None, Adjournment application rejected Date of Hearing 03.02.2026 Date of Pronouncement 25.02.2026

ORDER

PER AMITABH SHUKLA, AM, These three appeals by the assessee are directed against the separate orders of learned Principal Commissioner of Income Tax, Rohtak, [hereinafter referred to as ‘ld. PCIT] dated 27.03.2025 arising out of assessment order dated 20.10.2022 and 21.10.2022 passed under section 147 r.w.s. 144B of the Income Tax Act, 1961(hereinafter referred to as ‘the Act’) for the Assessment Years

2014-15, 2015-16 and 2016-17, respectively.

2. The assessee has raised following grounds of appeal for AY 2014-15:-

“1. That the assessment order passed and various additions/ disallowances made are arbitrary and contrary to Law and Facts of the case.

2. That the Ld. Assessing Officer had acted unreasonable in contravention of the provisions of the Income Tax Act, 1961 while considering the explanation of the assessee.

3. The learned Principal Commissioner of Income Tax has erred in not considering the plea of the appellant that the proceedings could not be initiated under Section 263 of the Income Tax Act when all the required verifications were already done during the assessment proceedings and thus the proceedings could not have been initiated again on the same cause of action. The Principal Commissioner of Income Tax ought to have considered that when the Assessing Authority has already done complete scrutiny then it is not understood as to how on the same very aspect the proceedings can again be initiated by the department.”

3. All the above three appeals of the assessee are regarding invocation of revisionary authority under section by the ld. PCIT, Rohtak. The ld. Counsel for the assessee submitted that facts of all the three assessment years are identical and hence for the purposes of convenience, the three appeals were heard and are being adjudicated by this common order.

4. For the purposes of this order, we will consider the facts and figures in ITA No.3419/Del/2025. As per brief factual matrix of the case, return declaring income of Rs.60,68,160 was filed by the assessee for AY 2014-15 on 24.09.2014. Order under section 143(3) was passed on 26.08.2016, assessing total income at Rs.64,45,950/-. Subsequently, based upon the information received by the ld. AO, reassessment proceedings under section 147 were initiated and consequently order under section 147 r.w.s. 144B was passed on

21.10.2022 determining total income at Rs.11,47,98,412/-.

5. Para-2.1 of the order of the PCIT, dated 27.03.2025 (supra) alludes that the notice under section 263 of the Act was issued by him deeming order under section 147 r.w.s. 144B of the Act dated 21.10.2022 as erroneous. He had concluded that the same was passed without proper enquiry or verifications. Para-2 of the impugned order further alludes that the issuance of the notice under section 263 of the Act was related to his following observations.

“2. Upon examination of the assessment records for A.Y. 2014-15, it has been observed that:-

i) the company assessee has shown following details in the Balance Sheet as on 31.03.2024 As per provisions of section 56(2)(viib) of the Income Tax Act, 1961, where a company, not being a company in which the public are substantially interested, received, in any previous year, from any person being a resident, any consideration for issue of shares that exceeds the face value of such shares, the aggregate consideration received for such shares as exceeds, the fair market value of the s