IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA No.362/PUN/2025 िनधा(cid:6981)रण वष(cid:6981) / Assessment Year : 2018-19 MCM Developers, Vs. DCIT, Central Circle-1, nd

2 Floor, Tapadiya Aurangabad.

Terraces, Adalat Road, Aurangabad- 431001.

PAN : AAXFM0436D Appellant Respondent Assessee by : Shri Pramod Shingte Revenue by : Shri Amol Khairnar Date of hearing : 07.08.2025 Date of pronouncement : 17.09.2025 आदेश / ORDER PER VINAY BHAMORE, JM:

This appeal filed by the assessee is directed against the order dated 16.12.2024 passed by Ld. CIT(A), Pune-12 [‘Ld. CIT(A)’] for the assessment year 2018-19.

2. The appellant has raised the following grounds of appeal :-

“1. On the facts and in the circumstances of the case and in law the lower authorities erred in passing, a rectification order under section 154 dated 11/09/2021, thereby changing the section for initiating the penalty action, from Section 269ST to 269SS and further changing the initiating of penalty section from Section 271DA to 271D. The action cannot be considered as apparent mistake rectifiable under Section 154, as