In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh(Through Virtual Hearing) Shiva Preservation Pvt. Ltd, Vs. Ito, Kaist, Jawantnagar, Etawah, Ward-2(2)(5), Uttar Pradesh -206245 Etawah (Appellant) (Respondent) Pan: Aaecs3418D Assessee By : Shri Rajesh Malhotra, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/11/2025 Date Of Pronouncement /11/2025

271(1)(c ) of the Act in the facts and circumstances of the instant case. 4. I have heard the rival submissions and perused the materials available on record. The return of income for the assessment year 2014-15 was filed by the Assessee Company on 15-11-2014 declaring total income of Rs. Nil under normal provisions