IN THE INCOME TAX APPELLATE TRIBUNAL “C’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI,VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER IT(IT)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore

87, 2^nd Stage and Phase Mahalakshmipuram

2nd Stage, 14th Main, West of Chord ITO Road Vs. Ward International Taxation 1(2)

Mahalakshmipuram Bangalore Bangalore 560 086 PAN NO :BLRPN0428A APPELLANT RESPONDENT Appellant by : Sri Siddesh N Gaddi, A.R.

Respondent by : Dr. Divya K.J., D.R.

Date of Hearing : 07.08.2025 Date of Pronouncement : 04.11.2025

O R D E R

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the Income Tax Officer, Ward- International Taxation 1(2), Bengaluru dated 15.1.2025 vide DIN & Order No. ITBA/AST/S/147/2024-25/1072202882(1) passed u/s 147 r.w.s 144 of the Income Tax Act, 1961 (in short “The Act”) for the assessment year 2018-19.

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

3. The brief facts are that the case of the assessee was reopened u/s. 147 of the Act after following the due procedure as envisaged u/s. 148A of the Act. Accordingly, notice u/s. 148 of the Act was