ORDER

PER RAVISH SOOD, JM:

The captioned appeals filed by the assessee are directed against the orders passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 28/08/2025, which in turn arises from the respective orders 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 27/01/2024 and under section 271(1)(c) of the Act, dated 29/07/2024 for the Assessment Year (AY) 2015-16. As common issues are involved in the present appeals, the same are being taken up and disposed of vide a consolidated order. We shall first take up the quantum appeal in ITA No.2156/Hyd/2025, wherein the impugned order of the CIT(A) has been assailed on the following grounds of appeal:

“Ground No. 1 Non service of mandatory notice u/s 148A(b) The learned CIT(A) erred in law confirming Order of AO without considering the facts in assuming jurisdiction u/s 148 without effecting valid service of the mandatory show cause notice u/s 148A(b). The alleged notice dated 24/03/2022 was never served either by email OR by post and therefore no opportunity as mandated in section 148A(b) was pr