IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER & SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER I.T.A. No. 120/Ahd/2024 (Assessment Year: 2016-17)

Amee Govindbhai Patel, Vs. Income Tax Officer, 16, Utkarsh Society, Opp. Market Ward-1, Yard, Tal. Visnagar, Mehsana Dist. Mehsana, Gujarat-384315 [PAN No.CURPP4493D]

(Appellant) .. (Respondent Appellant by : Shri Dhinal Shah, AR Respondent by : Shri Abhijit, Sr. DR Date of Hearing 30.06.2025 Date of Pronouncement 18.09.2025 O R D E R PER: ANNAPURNA GUPTA - AM:

The present appeal has been filed by the assessee against the order passed by the Ld. Commissioner of Income Tax (Appeal), (hereinafter referred to as “CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi dated 29.11.2023 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2016-17.

2. Grounds raised by the assessee are as under:

“1. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A) has erred in confirming the reopening of assessment under section 147 of the Act in as much as there is no escapement of income and that the