THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC” BENCH Before Ms. Suchitra Kamble, Judicial Member Assessment Year 2019-20

Assessee by: Shri Mehul Thakkar, A.R.

Revenue by: Shri Suresh Chand Meena, Sr. D.R.

Date of hearing : 01-12-2025 Date of pronouncement : 16-01-2026 आदेश/ORDER This is an appeal filed against the order dated 24-06-

2025 passed by National Faceless Appeal Centre(NFAC), Delhi for assessment year 2019-20.

2. The grounds of appeal are as under:-

“1. The Ld. Assessing Officer has erred in law and on facts in reopening the assessment under section 147 of the Act. The reopening is bad in law and void ab initio.

2. The Ld. Assessing Officer has erred in issuing notice under section 148A(b) without furnishing complete relied-upon documents and without disposing of the objections of the appellant by way of a reasoned and speaking order.

3. The order passed under section 148A(d) of the Act by the Ld. Assessing Officer is bad in law, as it has travelled beyond the scope of the Show Cause N