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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
SMT. BEENA PILLAI, J, SMT. REN JUHRI, ACJ
RATAN N MOTWANI (HUF) MUMBAI – Appellant
Versus
ITO WARD 23(3)(1) MUMBAI – Respondent
| Table of Content |
|---|
| 1. appeal details and grounds raised (Para 1 , 2) |
| 2. introduction of facts related to the case (Para 3) |
| 3. arguments presented by both parties regarding section approvals (Para 4 , 5) |
| 4. court's conclusion on the authority designated for approval (Para 6) |
| 5. final result of the appeal (Para 7) |
आदेश/ORDER
PER RENU JAUHRI [A.M.] :-
This appeal is filed by the assessee against the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] dated 29.08.2025 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Year [A.Y.] 2017-18.
2. The grounds of appeal are as follows:
“1. On the facts and circumstances of the case and in law, the CIT (A) ought to have considered the notice issued under Section 148 on 27-7-2022 as invalid and bad in law in view of the fact that it was issued after the expiry of the time period as extended by the provisions of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 after excluding the period referred to in third proviso to Section 149 as explained by the Supreme Court in the case of UOI v. Rajeev Bansal [2024] 167 taxmann.com 70 (SC). As
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