IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT &

MS PADMAVATHY S, ACCCOUNTANT MEMBER I.T.A. No. 3855/Mum/2025 (Assessment Year: 2018-19)

Aqua Tech Solutions Private PCIT (Central)-3, Mumbai Limited 441, 4^th Floor, Kautilya Bhavan, Vinayak Shramik Co-op. Society, C -41 to C-43, G Block, Bandra Vs.

Sr. No. 128/1B Paud Road, K urla Complex, Bandra (East), Kothrud, Pune Mumbai- Mumbai- 400051 PAN: AAGCA3182L Appellant) : Respondent Assessee by : Ms. Simran Dhawan &

Shri. Ravi Ganatra Revenue by : Shri. Rajesh Kumar Yadav, CIT. DR Date of Hearing : 19.11.2025 Date of Pronouncement : 09.12.2025 O R D E R Per Padmavathy S, AM:

This appeal by the assessee is against the order of the Principal Commissioner of Income Tax Appeals/National Faceless Appeal Centre (NFAC), Mumbai-3 passed u/s. 263 of the Income Tax Act, 1961 (the 'Act') dated

31.03.2025 for AY 2018-19. The grounds raised by the assessee are as under –

“1. On the facts and in the circumstances of the appellant's case and in law,

the Ld. Principal Commissioner of Income Tax, erred on facts and in law in

invoking provisions of section 263 of the Income Tax Act, 1961 which is

illegal, bad-in-law