AGGARWAL IRON & STEEL CORPORATION, LUDHIANA,LUDHIANA vs. JAO INCOME TAX OFFICER WARD 5(1), LUDHIANA, LUDHIANA

आयकर अपीलीय अिधकरण,च�ीगढ़ �ायपीठ “ए” , च�ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: HYBRID MODE �ी लिलत कुमार, �ाियक सद� एवं �ी िवजय वमा� , लेखा सद� BEFORE: SHRI. LALIET KUMAR, JM & SHRI. VIJAY VARMA, AM आयकर अपील सं./ ITA No. 903 /Chd/ 2026 िनधा�रण वष� / Assessment Year : 2022-23 Aggarwal Iron & Steel Corporation बनाम The ITO 142-143 R, Industrial Area-B, Ward 5(1) Overlock Road, Ludhiana East, Ludhiana Ludhiana, Punjab-141003 �ायी लेखा सं./PAN NO: AABFA6363P अपीलाथ�/Appellant ��थ�/Respondent िनधा�रती की ओर से/Assessee by : Shri Sudhir Sehgal, Advocate राज� की ओर से/ Revenue by : Smt. Jaishree Sharma, CIT, D.R (Virtual) सुनवाई की तारीख/Date of Hearing : 25/08/2026 उदघोषणा की तारीख/Date of Pronouncement : 02/09/2026 आदेश/Order PER VIJAY VARMA, A.M: This is an appeal filed by the assessee against the order under section 263 passed by the Ld. PCIT, Ludhiana-1 dt. 12/03/2026 for the Assessment Year 2022-23. 2. There was a discrepancy of Rs. 20408096/- pointed out by the Ld. PCIT which is mentioned on page 1 of the show cause notice dt. 26/11/2025 under section 263 which reads as under:

Sales as per column 34(a) of Form 3CD on which TCS collected 138791962 Party wise detail other than TCS as submitted during assessment 188519782 proceedings Total Sale 327311744 On scrutiny of Profit and loss account forming part of the Balance Sheet as on 31st March 2022 revealed that total sale was booked as 306903648/- as against 327311744/- which was short by Rs. 20408096/-. The difference amount in sales was not enquired or verified by AO.

2 4. The Ld. PCIT restored the matter back to the AO on three issues mentioned in para 9 of the order: 9. In exercise of the powers conferred under Section 263 of the Income Tax Act, 1961, the assessment order dated 17.03.2024 passed by the Assessing Officer under Section 143(3) read with Section 144B of the Income Tax Act, 1961 for Assessment Year 2022-23 is hereby set aside. The Assessing Officer is directed to frame the assessment afresh de novo after conducting necessary enquiries and verification, particularly with regard to: 1. Reconciliation of sales disclosed in the Profit and Loss Account with the sales reported in Form 3CD(Clause 34). 2. Verification of the Goods and Services Tax component included in the reported figures. 3. Examination of Tax Collected at Source compliance under Section 206C of the Income Tax Act, 1961. 4. Verification of the alleged clerical error in the Tax Collected at Source returns.

“ In continuation of our Brief Synopsis filed on 23.06.2026, it is submitted that the so- called impugned difference of Rs. 2,04,08,096/- is merely on account of inclusion of the GST on the sales (as tabulated below) while reporting the figures of sales in Sl. 34 of tax audit report and the details of the same is as under: Nature of Sales Amount of GST Paperbook Goods sold against 27C 1,95,94,312/- 54 Goods sold and TCS collected 17,14,783/- 55 Total 2,13,09,095/- Less: 9,01,000/- Difference 2,04,08,096/-

3 8. The Ld. DR on the other hand relied on the order of the Ld. PCIT. 9. The rival contentions have been examined. It is true that there has been a difference in the figure of sales which the AO failed to examine. However, the difference on account of GST was explained before the Ld. PCIT and is also evident from the record. Therefore we uphold the order of the Ld. PCIT. However, in the reassessment proceedings consequent to the order under section 263, only the issue related to the difference of Rs. 9,01,000/- shall be examined. Therefore, we are restricting the scope of enquiries and verification in the assessment proceedings consequent to the order under section 263. In the individual ground of appeal, the assessee has mainly raised the contention regarding validity of the order under section 263, which we have upheld. However, we have restricted the scope of inquiries and verification in the assessment proceedings consequent to order under section 263. Therefore for statistical purposes the appeal is treated as dismissed. Though the assessee gets a partial relief in the sense that the scope of inquiries have been restricted.

Order pronounced on 02/09/2026 Sd/- Sd/- लिलत कुमार िवजय वमा� (LALIET KUMAR) (VIJAY VARMA) �ाियक सद� /JUDICIAL MEMBER लेखा सद�/ ACCOUNTANT MEMBER AG आदेश की �ितिलिप अ�ेिषत/ Copy of the order forwarded to : 1. अपीलाथ�/ The Appellant 2. ��थ�/ The Respondent 3. आयकर आयु�/ CIT 4. आयकर आयु� (अपील)/ The CIT(A) 5. िवभागीय �ितिनिध, आयकर अपीलीय आिधकरण, च�ीगढ़/ DR, ITAT, CHANDIGARH 6. गाड� फाईल/ Guard File

BY ORDER, ASSISTANT REGISTRAR INCOME TAX APPELLATE TRIBUNAL KENDRIYA SADAN, SECTOR-9A CHANDIGARH