IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘A’ BENCH, LUCKNOW BEFORE SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER A.Y. 2015-16 Vikas jain, vs. The ACIT, PHA-2N/:1 A, KBiQdPwJa8i0 N4a9gRar , Kanpur- Circle 2(1)(1), Kanpur 208001

208006 (Appellant) (Respondent)

Assessee by: Sh. Rakesh Garg, Adv Revenue by: Sh. Amit Kumar, DR Date of hearing: 07.10.2025 Date of pro nouncement: O R D3 1E. 1R2 .2025 PER NIKHIL CHOUDHARY, A.M.:

This is an appeal filed by the assessee against the orders of the ld. CIT(A), NFAC on 17.05.2024 wherein the ld. CIT(A) has dismissed the appeal of the assessee against the order passed by the ld. Assessing Officer under section 147 r.w.s. 143(3) for the A.Y. 2015-16 on 27.12.2018. The grounds of appeal are as under:- 01. Because there being no reason to believe, far from there being any material to form reasons to believe, the proceedings initiated right from issue o“f notice u/s. 148 and the re-assessment framed thereof are all without jurisdiction bad in law, the order passed be quashed.

02. Because the so-called reasons having been recorded applying Explanation 2(a) to Section 147, of the Act which not being applicable, the very rea