आदशे / O R D E R PER ABY T. VARKEY, JM:

This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as ‘Ld.CIT(A)‘), Delhi, dated 28.07.2025 for the Assessment Year (hereinafter referred to as ‘AY‘) 2020-21.

2. At the outset, the Ld.AR of the assessee brought to our notice that the appeal has been filed belatedly by ‘16’ days and for condoning the delay, the assessee has filed an affidavit explaining the cause for the delay. Having gone through the contents of the same, we find that cause for delay was reasonable, so we excuse the same and proceed to hear the assessee’s appeal.

3. The Ld.AR of the assessee drew our attention to grounds of appeal preferred by it wherein assessee has raised a legal issue challenging the notice issued by the Jurisdictional Assessing Officer (hereinafter referred to as ‘JAO‘) u/s.148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act ‘) dated 30.03.2024 as bad in law and hence according to him, consequent passing of the assessment order by the Assessing Officer also is null in the eyes of law.

4. According to the Ld.AR, the impugned notice issued u/s.148 dat