ORDER

PER MANISH AGARWAL, AM:

This appeal is filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A) in short], dated 17.02.2025 in Appeal No. NFAC/2014-15/10282979 arising out of the assessment order passed u/s 147 r.w.s. 144 dated 19.05.2023 for Assessment Year2015-16.

2. Brief facts of the case are that case of the assessee was reopened on the basis of information received that there were larger credits in the bank account of the assessee and there is mismatch in the income declared by the assessee and credits in the bank account and accordingly, notice u/s 148 was issued on 06.04.2021. Thereafter, in terms of the order of Hon’ble Supreme Court in the case of Union of India vs. Ashish Agarwal and Ors. in Civil Appeal No. 3005/2002, the said notice was treated as notice u/s 148A(2) of the Act. After passing the order u/s 148A(d) of the Act, a fresh notice u/s 148 w