IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2018-19 Sh. Rakesh, Vs. Income Tax Officer, D-65, Pinces Park, Ward-43, Copernicus Marg, Delhi Delhi PAN: BWPPR4036R (Appellant) (Respondent)

Assessee by Sh. Shikhar Garg, CA Department by Sh. Manoj Kumar, Sr. DR Date of hearing 25.11.2025 Date of pronouncement 25.11.2025 ORDER This assessee’s appeal for assessment year 17.09.2025, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1080824203(1), dated 17.09.2025 involving proceedings under section 147 of the Income-

tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

2. It emerges during the course of hearing that there arises the first and foremost issue of validity of the impugned section 148A(d) proceedings herein itself initiated vide notice dated 08.04.2022 (page 29 of the paper-book) in assessment year 2018-19. This is for the precise reason that the learned Assessing Authority had obtained the necessary approval from the PCIT, Delhi-15