IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आयकर अपील सं./ITA No.222/RJT/2024 ((cid:467)नधा(cid:91)रण वष (cid:91)/ Assessment Year: (2019-20)

(Hybrid Hearing)

Sagar Jewellers Vs. DCIT Zaveri Bazar, Porbandar, Gujarat Circle-2(1), Jamnagar

360575 èथायीलेखासं./जीआइआरसं./PAN/GIR No.: ADBFS5410L (Assessee) (Respondent)

Assessee by : Shri K. C. Thaker, AR Respondent by : Shri Sanjay Punglia, CIT.DR Date of Hearing : 01/10/2024 Date of Pronouncement : 01/01/2025 आदेश / O R D E R PER DR. A. L. SAINI, AM:

By way of this appeal, the assessee has challenged the correctness of the order passed by the Learned Principal Commissioner of Income Tax (in short ‘the PCIT’), under Section 263 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), dated 21.02.2024, for the Assessment Year (in short ‘A.Y.’) 2019-20.

2. The grievances raised by the assessee are as follows:

1. The learned Pr. CIT has erred in law and on facts in holding that the order u/s. 143(3) dt. 16-09-2021 is erroneous in so far as it is prejudicial to revenue on the ground that tax was not charged u/s. 115BBE of the Act a