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2026 Supreme(Online)(ITAT) 12568

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
KPA APPARELS PRIVATE LIMITED DELHI – Appellant
Versus
INCOME TAX OFFICER WARD 14(3) DELHI – Respondent


ORDER

PER MANISH AGARWAL, AM:

This appeal is filed by the Assessee against the order of the Ld. Principal Commissioner of Income Tax, Delhi-4 [ld. PCIT, in short] dated 17.03.2025 in Revision No. PCIT, Delhi-4/Revision-263/100000777938/2025 passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) revising the Assessment Order passed u/s 143(3) of the Act dated 17.09.2022 for AY 2020-21.

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

“1. That on the facts and circumstances of the case and in law, the order dated 17.03.2025, passed by the Principal Commissioner of Income Tax, Delhi-4 ['Ld. PCIT'], under section 263 of the Income Tax Act, 1961 ('the Act') setting aside the assessment to be made de novo being without jurisdiction and unlawful is void ab initio and deserves to be quashed.

2. That the Ld. PCIT erred on facts and in law in exercising revisionary powers under section 263 of the Act on issues in the impugned order, without satisfying the twin jurisdictional conditions of the assessment order being: (a) erroneous; and (b) prejudicial to the interests of the Revenue and consequently, the impugned order being unlawful deserves to be quashed.

3. Tha

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