IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 1817/MUM/2025 (AY: 2022-23)

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Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER:

1. This appeal by assessee is directed against the final assessment order dated

14.01.2025 passed under section 143(3) r.w.s. 144C(13) passed in pursuance of direction of ld Dispute Resolution Penal (DRP) dated 18.12.024 for A.Y.

2022-23. The assessee in its appeal has raised following grounds of appeal:

“1. On the facts and in the circumstances of the case, and in law, the notice issued under section 143(2) of the Act, dated 31 May 2023, by the Assistant / Deputy Commissioner of Income-tax, 1(1)(1), Delhi, to initiate assessment proceedings for AY 2022-23, is without jurisdiction in terms of the Central Board of Direct Taxes order (No. F. No. 187/3/2020-ITA-I) dated 31 March 2021, and thus the assessment or