2026 (7) TMI 512

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....rkar for the appellant and learned Senior Standing Counsel Mr. Maunil Yajnik for the respondent. 2. By this appeal under Section 260A of the Income Tax Act, 1961 (for short 'the Act'), the appellant has proposed the following questions of law arising out of the order dated 12.02.2026 passed by the Income Tax Appellate Tribunal Rajkot Bench (for short 'the Tribunal') in ITA No. 363/RJT/2024 for Assessment Year 2018-19: "(A) Whether the Income Tax Appellate Tribunal erred in law in upholding the invocation of revisional jurisdiction under section 263 of the Income-tax Act, 1961, in a case selected for 'Limited Scrutiny' on the specific criterion of 'large share premium', when the Assessing Officer had raised specif....

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.... proposed questions of law. 4. With the consent of learned advocates appearing for the respective parties and considering the findings of the Tribunal, the appeal is taken up for final hearing. 5. The appellant-assessee being aggrieved by the order dated 31.03.2024 passed by the Principal Commissioner of Income Tax (for short 'PCIT') under Section 263 of the Act, preferred an appeal before the Tribunal. 6. The Tribunal, after considering the facts of the case dismissed the appeal. However, the Tribunal in Paragraph No. 23 of the impugned order has taken into consideration the assessment order passed by the Assessing Officer under Section 143(3) of the Act read with Section 263 of the Act dated 14.3.2025 to justify the action of the....