2025 (11) TMI 1006

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....Judicial Member For the Appellant : Shri Biren Shah, with Shri Gulab Thakor, ARs For the Respondent : Shri Ravindra, Sr. DR ORDER PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- This appeal is filed by the Assessee against the appellate order dated 18.06.2025 passed by the Commissioner of Income Tax (Appeals)National Faceless Appeal Centre, Delhi, relating to the Assessment Year 2017-18. ....

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....in not adjudicating ground relating to the validity of reassessment proceeding despite the fact that Notice issued u/s 148 by Jurisdictional Assessing officer is in violation of Section 151A of the Act and CBCT Notification No. 18/2022 dated 29.03.2022. 4 In law and in the facts and circumstances of the case, Ld. CIT(A) has grossly erred in not adjudicating ground relating to the validity....

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....notice u/s. 148) 30.06.2021 2. Due date of issuance of notice 30.06.2021 3. No. of days between date of original 148 and due date of issuance of noice u/s. 148 (deemed to be stayed, thus added in the total limitation) 1 Day 4. Date of filing of response to notice u/s. 148A(b) 27.07.2022 5. Date of limitation for issuing notice u/s. 148 27.07.2022 + 7 days = 0....