ORDER

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These appeals filed by the Revenue and Cross Objections filed by the assessee are against the orders of CIT (A) 57, Mumbai-

i) vide order No. ITBA/APL/S/250/2024-25/1074571063(1), dated 17.03.2025 passed against the assessment order of Income Tax Officer (International Taxation)-3(2)(1), Mumbai u/s. 147 r.w.s.144C(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 28.07.2023 for AY 2015-16.

ii) vide order No. ITBA/APL/S/250/2024-25/1074573456(1), dated 17.03.2025 passed against the assessment order of Income Tax Officer (International Taxation)-3(2)(1), Mumbai u/s. 147 r.w.s.144C(3) of the Act, dated 28.07.2023 for AY 2016-17.

2. Grounds taken by the Revenue are reproduced as under:

ITA No. 3674/MUM/2025

1. Whether on the facts and in the circumstances of the case and in law, the ld.CIT(A) was justified in quashing the notice u/s. 148 of the Act without appreciating the fact that the impugned notice which was deemed to have been issued under Section 148 A, would be governed by TOLA, 2020 and the limitation period from 01.04.2021 would get extended up to 30.06.2021 since because the time limit for issuing notice under