ORDER

PER MANISH AGARWAL, AM:

These two appeals are filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeals) National Faceless Appeal Centre (NFAC), Delhi [“CIT(A)”, in short] in Appeal No. NFAC/2012-13/10290290 and NFAC/2014-15/10290307, both dated 12.08.2025 u/s 250 of the Income Tax Act, 1961 (“the Act”) arising out of the orders passed u/s 147 of the Act dated 18.05.2023 and 24.05.2023 for Assessment Years 2013-14 and 2015-16 respectively.

ITA No. 6447/Del/2025 [AY 2013-14]

2. First we take appeal filed by the assessee for AY 2013-14 in ITA No. 6447/Del/2025 wherein Ground of appeal No. 1, the assessee has raised legal issue of limitations on account of issue of notice u/s 148 of the Act on 27.07.2022.

3. Heard the parties and perused the material available on record. It is observed that first notice u/s 148 was issued on 08.06.2021. Thereafter, the notice u/s 148A(b) of the Act was issued on 26.05.2022 asking the assessee to file the objections, if any, within a period of two weeks, which expires on 13.06.2022. The assessee had filed reply on 13.06.2022 and the order u/s 148A(d) was passed on 27.07.2022 and thereafter, the notice u/s 148 of the Act was i