A notice issued under the unamended Section 148 of the Income Tax Act that is served on or after April 1, 2021, must be treated as a show-cause notice under Section 148A(b), requiring compliance with the procedural mandates introduced by the Finance Act, 2021.

O R D E R

PER MANISH AGARWAL, AM:

This appeal is filed by the Assessee against the order of Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A) in short], dated 15.10.2025 in Appeal No. NFAC/2014-15/10120435 arising out of the order passed u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (the Act, in short) for Assessment Year 2015-16.

2. The assessee has challenged the appellate order only on the following grounds of appeal:

“JURISDICTION GROUNDS (IMPUGNED REOPENING ACTION U/s 148 IS TOTALLY INVALID)

10.1 That Impugned order passed u/s 250 by NFAC/CIT(A), dismissing appeal of assessee and sustaining Impugned assessment order of Ld. AO are totally unlawful as notice u/s 148 is issued under old law on 01-04-2021 for all practical purposes after enactment of new law from 01-04-2021 which is held as invalid as per jurisdictional high court decision of Sumanjeet Aggarwal (2022) 449 ITR 517;

10.2 That impugned order passed u/s 250 by NFAC/CIT(A), dismissing appeal of assessee and sustaining impugned assessment order of Ld. AO are totally unlawful as reasons recorded u/s 148(2) are completely vague regarding nature of subject transactions and merely recorded on stereotype language without own independent findings.

10.3 That Impugned order passed u/s 250 by NFAC/CIT(A), dismissing appeal of assessee and sustaining impugned assessment order of Ld. AG are totally unlawful as reopening is made on basis of borrowed satisfaction without Independent satisfaction as required in terms of section 148(2) of unamended act;

10.4 That Impugned order passed u/s 250 by NFAC/CIT(A), dismissing appeal of assessee and sustaining Impugned assessment order of Ld. AG are totally unlawful as complete reasons to believe along with stated back material forming part of reasons to believe is never confronted to the appellant in violation of settled precedents of the jurisdictional high court and supreme court;

10.5 That Impugned order passed u/s 250 by NFAC/CIT(A), dismissing appeal of assessee and sustaining Impugned assessment order of Ld. AO are totally unlawful as sanction obtained u/s 151 is very mechanical without any whisper of independent reasons;

10.6 That impugned order passed u/s 250 by NFAC/CITA, dismissing the appeal of the assesse and sustaining Impugned assessment order of Ld. AO (NFAC) Is unlawful as in violation of principles of natural justice:-

i) That there is no supply of relied upon material as per section 142 before passing assessment order and taking adverse view against the assessee.

ii) That there is no draft assessment order confronted or supplied to the assesse before passing final assessment order.

iii) That there is no opportunity of cross-examination provided to the assesse on specific request of the assesse despite reliance of the statement of third party le Bharat Bansal.

10.7 That Impugned order passed u/s 250 by NFAC/CIT(A), dismissing appeal of assesse and sustaining Impugned assessment order of Ld. AO (NFAC) are unlawful as there is no draft assessment order served on the assessee as per section without which entire assessment order passed is in teeth of section 1448 and therefore invalid

10.8 That Impugned order passed u/s 250 by NFAC/CIT(A), dismissing the appeal of the assesse and sustaining Impugned assessment order of Ld. AO (NFAC) is unlawful as no valid show cause notice has been issued before passing assessment order without which entire order has been passed in arbitrary and whimsical manner without authority of law.

That the appellant craves leave to add add/al