आदेश/ORDER 

PER ANIKESH BANERJEE [J.M]:

Instant appeal of the assessee was preferred against the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as "Ld. CIT(A)"] order passed u/s. 250 of the Income Tax Act, 1961 [hereinafter referred to as "Act"] order passed for the Assessment Year 2014-15 date of order 17.09.2025. The impugned order emanated from the order of the Ld. ITO-19(2)(1), Mumbai [hereinafter referred to as "Ld. AO"], order passed u/s.143(3) r.w.s. 147 date of order 30.12.2017.

2. The assessee has taken the following grounds:

“1. That on facts and circumstances of the case and in law the id. C.I.T. (Appeals), NFAC, Delhi has erred in not quashing the impugned assessment order dated 30/12/2017 passed u/s.143(3) r.w.s.147 by ld. Income Tax Officer-19(2)(1), Mumbai on either of or on all the following grounds:

i) That the impugned assessment order passed by Id. ITO-19(2)(1), Mumbai without recording his own reason to reopen the assessment and issuing any own notice u/s.148 but on the basis of reason recorded and notice issued u/s.148 by non-jurisdictional ITO-19(3)(1), Mumbai being without jurisdiction and void ab initio hence may be quashed an