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.612/Viz/2025 (िनधा१रण वष१/Assessment Year: 2016-17)

Venkata Prasad Pulipati, Vs. Income Tax Officer, Amaravathi. Ward-2(1), PAN: ASAPP8796L Guntur.

(Appellant) (Respondent)

िनधा१ौरती (cid:554)ारा/Assessee by: Shri I. Kama Sastry, CA राज(cid:830) व (cid:554)ारा/Revenue by: Dr. Aparna Villuri, Sr. AR सुनवाई की तारीख/Date of 03/12/2025 Hearing:

घोषणा की तारीख/Date of 19/12/2025 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 (Appeals), National Faceless Appeal Centre, (NFAC), Delhi, dated 18/09/2025, which in turn arises from the order passed by the Assessing Officer (for short, “A.O.”) under Section 147 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”) dated 30/05/2023 for the Assessment Year (AY) 2016-17. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

“1. The notice issued under section 148 dated 27.07.2022 is ba