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, Delhi, dated 11/09/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 24/02/2023 for the Assessment Year (AY) 2015-16. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

“1. The Ld. CIT(A) erred in facts and law while passing the order.

2. The Ld. CIT(A) has not considered that the learned AO as per his/her convenience very calculatedly assumed that the assessee" "chose to remain silent on the proposed action" and furnished no reply, despite "sufficient opportunity provided". It is to bring to your kind notice that the assessee has been an ardent taxpayer and ever since he got aware of the seriousness of the situation, all timely compliances have been made. The assessee has only received notice u/s 148 dated 30.07.2022 by post. All other notices were served to the email id maheshjaju@gmall.com.

The assessee in all good faith had