IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘A’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER A.Ys. 2014-15 & A.Ys. 2015-16 PSuApNe:r AhoAuBsCeS L9i3m2it8eKd , 150 Feet vs. The Commissioner of Income Tax Road, Jajmau, Kanpur-208010 International Taxation-3, Delhi (Appellant) (Respondent)

Assessee by: Sh. G.C. Srivastava, Adv & Sh. Kalrav Mehrotra, Adv Revenue by: Sh. R.K. Agarwal, CIT DR Date of hearing: 03.12.2025 Date of pro nouncement: O R D2 5E. 0R2 .2026 PER NIKHIL CHOUDHARY, A.M.:

These two appeals have been filed by the assessee against the orders of the CIT, (International Taxation)-3, Delhi passed under section 263 of the Act for the A.Ys. 2014-15 and 2015-16, both dated 29.03.2024, wherein the ld. CIT has set aside the earlier orders of the Assessing Officer for making of fresh orders in accordIaTnAc eN ow. i3th56 t/hLeK dWir/e2c0ti2o4n s issued by her. The grounds of appeal are as under:-

“1. BECAUSE, on the facts and circumstances of the case and in law, the Ld. CIT has erred in assuming jurisdiction under Section 263 of the Act and in doing so, has sought to substitute his opinion with the order under Section