2025 (11) TMI 2060

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....EEP GOSAIN, JM: This appeal has been filed by the assessee challenging the impugned order dated 01.09.2025 passed under section 250 of the Income Tax Act, 1961 ('the Act'), by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment year 2022 23. 2. At the outset, Ld. AR has raised the additional ground, wherein he has challenged the issuance of notice u/s 148 of the Act on the....

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....the assessee are reproduced herein below: Additional Ground. The Appellant/assessee craves for leave to raise and state additional ground(s), which concerns the issue of jurisdiction u/s. 147 and goes to the root of the matter. It is submitted that the issue(s) of jurisdiction can be raised for the first time before this Hon'ble Tribunal. It is submitted that: 1) Dat....

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.... As per the provisions of Sec. 151 of the Act, the appropriate authority for seeking approval is Pr. CIT whereas the AO has obtained approval of Pr. CCIT as mentioned in para 3 of the notice u/s 148 of the Act dated 22.07.2022. In this regard I have perused the provisions of Sec. 151 of the Act and also the decision of the Coordinate Benches of ITAT mentioned herein below: 1. Satish Harna....