ORDER

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. Income Tax Officer, Ward Intl. Taxation 1(2), Bangalore dated 17.12.2024 vide DIN & Order No. ITBA/AST/S/147/2024-25/1071274366(1) for the assessment year 2015-16.

2. The assessee has raised the following grounds of appeal:

3. Brief facts of the case are that the assessee is a non- Resident and did not file his return of income in India for the AY 2015-16 as his income in India was way below the taxable limit chargeable to tax in India. The case of the assessee was re-opened u/s. 147 of the Act after following due procedure as envisaged u/s. 148A of the Act. Accordingly, a notice u/s. 148 of the Act was issued to the assessee on 19/04/2022. In response to the notice u/s. 148 of the Act, the assessee filed his return of income on 18/05/2022 declaring total income of Rs.1,91,920/-. Accordingly, the notices u/