आयकर अपीलीय अिधकरण, िवशाखापटणम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench, Visakhapatnam Before Shri Ravish Sood, Judicial Member and Shri Balakrishnan S., Accountant Member आ.अपी.सं /ITA No.491/Viz/2025 (िनधा१रण वष१/Assessment Year: 2016-17)

Satyanarayana Koduru, Vs. Income Tax Officer, Krishna District. Ward-1, PAN:ALTPK1048C Gudiwada.

(Appellant) (Respondent)

िनधा१ौरती (cid:554)ारा/Assessee by: Shri C. Subrahmanyam, CA राज(cid:830) व (cid:554)ारा/Revenue by: Dr. Aparna Villuri, Sr. AR सुनवाई की तारीख/Date of 02/12/2025 Hearing:

घोषणा की तारीख/Date of 05/12/2025 Pronouncement: आदेश / ORDER PER. RAVISH SOOD, JM :

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax, National Faceless Appeal Centre, Delhi, dated 01/07/2025, which in turn arises from the order passed by the Assessing Officer (for short, ”AO”) under Section 147 r.w.s 144 r.w.s 144B of the Income-tax Act, 1961 (for short, “Act”), dated 10/01/2024, for the Assessment Year 2016-17. The assessee has assailed the impugned order of the CIT(Appeals) on the following grounds of appeal before us.

“1) That on the facts and circumstances of the case and in l