ORDER

PER: RATHOD KAMLESH JAYANTBHAI, AM

By way of present appeal, the above named assessee challenges the order of the National Faceless Appeal Centre, Delhi [ for short CIT(A) ] dated 24/10/2024 for the assessment year 2017-18. Ld. CIT(A) passed that order because the assessee has challenged the order of assessment dated 11.05.2023 passed under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 [ for short “Act”] which was passed by the Assessment Unit of Income Tax Department [ for short AO].

2. In this appeal, the assessee has raised the following grounds: -

“1. That the whole proceedings u/s 147/148 are liable to be held as null and void as the same have been taken ignoring the provisions of section 153C of the Income Tax Act, 1961 which has over riding effect over provisions of section 147/148.

2. That the whole proceedings undertaken u/s 147/148 are vitiated on account of following reasons:-

a. Notice has been issued without jurisdiction and proper sanction. Notice is not as per provisions of law as amended w.e.f. 01.04.2021. Further the new notice dated 28.07.20922 is also without proper sanction as per section 151 of the Income tax Act, 1961.

b. The condition of Sec