IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER &

SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No.2065/Ahd/2025 (Assessment Year: 2021-22)

Kiri Industries Ltd., Vs. Deputy Commissioner of

7^th Floor,Hasubhai Chambers, Income Tax, Nr. Town Hall, Ellisbridge S.O., Circle-2(1)(1), Ahmedabad-380006 Ahmedabad [PAN No.AAACK9025C]

(Appellant) .. (Respondent Appellant by : Shri Tushar Hemani, Sr. Adv.

Respondent by: Shri Rameshwar P Meena, Sr. DR Date of Hearing 01.04.2026 Date of Pronouncement 22.04.2026

O R D E R

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 13.08.2025 passed for A.Y. 2021-22.

2. The assessee has raised the following grounds of appeal:

“1. The Ld. CIT(A) and Ld. AO has erred in law and on facts in disallowing expenses claimed as commission paid on exports of-Rs.88,61,356 u/s 40(a)(i) of the Act, on account of non-deduction of tax at source.

2. The Ld. CIT(A) and Ld. AO has erred in law and on facts in disallowin