IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI MANJUNATHA G., ACCOUNTANT MEMBER Assessment Year: 2013-14 Pradip Kumar Agarwal (HUF) ITO, Ward-30(1), Kolkata Vs

1B, Deodhar Street, Ballygunge, Kol-700029.

(PAN: AAKHP4733P)

(Appellant) (Respondent)

Assessee by : Shri Miraj D. Shah, Advocate Revenue by : Shri S.B. Chakraborty, Sr. DR Date of Hearing : 06.04.2026 Date of Pronouncement : 06.04.2026

ORDER

Per George Mathan, JM This is an appeal filed by the assessee against the order of the Commissioner of Income Tax (Appeals), NFAC, Delhi [hereinafter referred to as the ‘CIT(A)’] in appeal no.NFAC/2012-13/10259552 dated

19.12.2025 for the assessment year 2013-14.

2. Shri Miraj D. Shah, Advocate, represented on behalf of the assessee and Shri S.B. Chakraborty Sr. DR represented on behalf of the revenue.

3. At the outset, it was submitted by the ld. AR that the notice u/s 148 was issued on 28.07.2022 and the order u/s 148A(d) of the Act has been passed on 28.07.2022 for the assessment year 2013-14 which is beyond the TOLA period. It was the submissions that as per the decision of Apex Court, notice under the old regime can only be issu