आदेश/ ORDER

PER DR. DIPAK P. RIPOTE, AM:

This is an appeal filed by the Assessee against the order of ld.Commissioner of Income Tax(Appeal)[NFAC], passed under section 250 of the Income Tax Act, 1961 for the A.Y.2015-16 dated 11.07.2025 emanating from the Assessment Order passed under section 147 read with section 144B of the I.T.Act, dated 15.11.2023. The Assessee has raised the following grounds of appeal :

“1. On the facts and in the circumstances of the case and in law, Ld. AO erred in initiating the reassessment proceedings u/s. 147 and consequential order passed u/s 147 rws 144 are bad in law as the notice u/s 148 was issued by Income Tax Officer, (Jurisdictional Assessing Officer-JAO) and the assessment order is completed by Faceless Assessing Officer-FAO which is not permitted as per provisions of section 151A and therefore entire proceeding are void-ab-initio and therefore consequential order are bad in law

2. The notice issued u/s 148 in the instant case is bad in law, being not issued through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148 of the Act and therefore, the order passed u/s 147 rws 1448 may b