IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER &

SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER आयकर अपील स.ं /ITA No.833/SRT/2024 Assessment Year: (2017-18)

(Physical hearing)

ITO, बनाम/ Deepesh Vishnu Agarwal, Ward – 1(2)(1), Vs. A/301, Surya Plaza, Surat City, Surat Magdalla B.O., Surat - 395007 èथायीलेखासं./जीआइआरसं./PAN/GIR No: AISPA2948P (Appellant) (Respondent)

Appellant by Shri Ajay Uke, Sr. DR Respondent by Shri Ramesh Malpani, CA Date of Hearing 01/09/2025 Date of Pronouncement 15/11/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM:

This appeal by the revenue emanates from the order passed under section

250 of the Income-tax Act, 1961 (in short, 'the Act’) dated 12.06.2024 by the Commissioner of Income-tax (Appeals), National Face Less Appeal Centre (NFAC), Delhi [in short, ‘CIT(A)’] for the assessment year (AY) 2017-18.

2. The grounds of appeal raised by the assessee appeals are as under:

“i. On the facts and circumstances of the case and in law, Ld. CIT(A) has erred in allowing the appeal of the assessee by holding notice issued u/s 148 of the Act invalid even though the notice was issued as per Instruction No. 01/2022 of