IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER I.T.A No.6481/Mum/2025 (Assessment Year: 2015-16)

Assessee by : Shri Bharat Kumar Respondent by : Shri Hemanshu Joshi (SR DR)

Date of hearing : 22/01/2026 Date of pronouncement : 29/01/2026 O R D E R PerAnikesh Banerjee(JM):

The instant appeal of the assessee filed against the order of NFAC, Delhi [for brevity, ‘Ld.CIT(A)’] order passed under section 250 of the Income-tax Act, 1961 (for brevity, ‘the Act) for the Assessment Year 2015-16, date of order 29/09/2025. The impugned order emanated from the order of the Learned Assessment Unit, Income-tax Department (for brevity, ‘the Ld.AO’) order passed u/s147 r.w.s. 144Bof the Act, date of order 23/05/2023.

2. We heard the rival submission and considered the documents available in the record. The Ld. AR placed the ground and with additional ground before the ITAT. Related to additional ground the assessee challenged the jurisdiction of the Ld. AO for issuance notice under section 148 on the deceased person Late Haresh I Chhugani. The representative of the deceased person Mrs. Shib