ORDER

PER SUCHITRA KAMBLE, JUDICIAL MEMBER:-

These three appeals filed by three different assessees against the separate orders all dated 22-07-2025 passed under Section 263 of Income Tax Act, 1961 (in short ‘the Act’) by the Principal Commissioner of Income Tax, Valsad (in short ‘the Pr.CIT’) for assessment year 2017-18.

2. The grounds of appeal raised by all three assessees are as under:

Grounds of appeal in ITA No.851/SRT/2025 in case of Dayaram Brijbhukhandas

“1. On the facts and in the circumstances of the case as well as law on the subject, the learned PCIT, Valsad has erred in invoking provisions of Section 263 of the Act without satisfying the twin conditions of the order being both "Erroneous" and "Prejudicial to the interest of Revenue". The impugned order is bad in law, void ab initio, and liable to be quashed.

2. The Learned PCIT, Valsad has erred in assuming jurisdiction under section 263 even though assessment order was passed after making detailed inquiries and examination by AO. In the present case, AO issued a detailed questionnaire on the issue of cash deposit made by the appellant firm during the year under consideration and proper submission was made by assesse inclu