ORDER

This assessee’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1076992154(1), dated 13.06.2025 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

2 For the reasons stated in the assessee’s condonation averments, delay of 139 days in filing of the instant appeal is condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

3. It emerges during the course of hearing that there arises the first and foremost issue of validity of the impugned section 148A(b) proceedings herein itself initiated vide notice dated 24.05.2021 in assessment year 2016-17. This is for the precise reason that the learned Assessing Authority had obtained the necessary approval from the Principal Commissioner of Income Tax, Delhi-15, than the prescribed authority under section 151(ii) of the Act i.e. Principal Chief Commissioner or……………………., if more than three years have elapsed from the end of the relevan