IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2018-19 Sh. Vimlesh Ahuja, Vs. Income Tax Officer, 1/43, Nirankari Colony Ward-36(1), Delhi- 110009 Delhi PAN: AAEPA7795G (Appellant) (Respondent)

Assessee by Sh. Pranav Yadav, Adv.

Department by Sh. Ravi Kant Chaudhary, Sr. DR Date of hearing 06.04.2026 Date of pronouncement 06.04.2026 ORDER This assessee’s appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1084769625(1), dated 14.01.2026 involving proceedings under section 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

2. It emerges during the course of hearing that there arises the first and foremost issue of validity of the impugned section48A(b)

proceedings herein itself initiated vide notice dated 04.04.2022 in assessment year 2018-19. This is for the precise reason that the learned Assessing Authority had obtained the necessary approval from the Principal Commissioner