IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil Kumar, Judicial Member ITA Nos. : 839/Ahd/2023 & 94/Ahd/2024 Assessment Year: 2014-15 Sahajanand Laser Assistant Technology Limited Vs Commissioner of

30, GIDC Electronics Income Tax, Estate, Sector-26, Circle-4(1)(1), Gandhinagar, Ahmedabad Gujarat-382028 PAN: AAGCS1983B The ACIT, Vs Sahajanand Laser Gandhinagar Circle, Technology Ltd Gandhi Nagar E-30,GIDC, Sector-

26, Gandhi Nagar, Gujarat-382028 PAN: AAGCS1983B (Appellant) (Respondent)

Assessee Represented: Ms. Arti N Shah, A.R.

Revenue Represented: Shri Prathvi Raj Meena, CIT-DR Date of hearing : 11-02-2026 Date of pronouncement : 09-03-2026 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

These cross appeals are filed by the Assessee and Revenue as against appellate order dated 21-08-2023 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “CIT(A)”), arising out of the assessment order passed under section 143(3) rws 263 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2014-15.

2. Brief facts of t