Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

reassessment proceedings and disallowed 100% of the purchases amounting to ₹77,61,745/- . The Principal Commissioner has not disputed the quantum of disallowance made by the Assessing Officer. The sole basis for invoking section 263 is that, according to the Principal Commissioner, the disallowance should have been made under section 69C