IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “SMC”, NEW DEALHI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER (Assessment Year: 2016-17)

(Physical hearing)

Bhagirathi Krishnan, Income Tax Officer, Ward-35(5), C/o-Anil Jain DD & Co. 611, 6^th Floor, Vs Civic Centre, Surya Kiran Building, 19- K.G. Marg, New Delhi-110002 New Delhi-110001 PAN:AQZPK1479J Appellant / Assessee Respondent / Revenue Assessee by Shri Anil Jain, CA &

Shri Pritam Kumar, Adv.

Revenue by Shri Virender Kumar Singh, Sr. DR Date of Institution of appeal 29.10.2025 Date of hearing 01.12.2025 Date of pronouncement 01.12.2025 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER;

1. This appeal by assessee is directed against the order of learned CIT(A)/National Faceless Appeal Centre, Delhi dated 04.09.2025 for assessment year (AY) 2016-17. The assessee has raised following grounds of appeal:

“1. That on the facts and circumstances of the case and the provision of law, the Ld. CIT(A) has failed to appreciate the fact that the initiation of proceeding u/s 147 is illegal, bad in law, without jurisdiction and time barred and thus assessment order passed requires to be quashed.

2. That on the facts and ci