IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM ITA No.763/KOL/2024 (Assessment Year: 2018-19)

Nadia District Central Co-

PCIT-1, operative Bank Ltd.

Aaykar Bhavan, P-7, Samabay Building M.M. Ghosh Chowringhee Square, Street, Krishnanagar, Vs.

Kolkata-700069 Kolkata-741101 West Bengal West Bengal (Appellant) (

Respondent)

PAN No. AAALN0139M Assessee by : Shri S.K. Tulsiyan, AR &

Shri P.K. Roy & Puja Somani, ARs Revenue by : Shri P.N. Barnwal, DR Date of hearing: 07.01.2025 Date of pronouncement : 15.01.2025

O R D E R

Per Rajesh Kumar, AM:

This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 21.12.2023 for the AY 2018-19.

02. The assessee has challenged the exercise of revisionary jurisdiction by ld. PCIT u/s 263 of the Act as invalid without satisfying twin conditions as envisaged u/s 263 of the Act. Besides the assessee has raised an additional ground of appeal, which is extracted below:-

“That the ld. AO erred in issuing notice u/s 143(2) of the Act dated 22.09.2019

without complying to the CBDT Instruction F.No.225/