आदेश/ORDER

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 11.11.2025 of the learned CIT(A)--National Faceless Appeal Centre [in short “NFAC], Delhi, for the assessment year 2015-2016.

2. The assessee has raised the following grounds of appeal:

1. “The order passed by the learned CIT(A) of National Faceless Appeal Centre u/s 250 is bad in law and on fact unjust and unwarranted. Hence the Appellant prays the Honorable Income Tax Appellate Tribunal to quash the order and DLEETE the addition made.

2. The notice u/s 148A(b) has been issued without providing mandatory time of 7 clear days as provided in Sec. 148A(b) and hence order passed u/s 148A(d) and notice issued u/s 148 basing on such order is bad in law. Proceedings conducted on an invalid notice are void ab initio.

3. The Appellant submits that the notice dated 13.04.2022 issued u/s 148 itself is invalid as the notice is barred by limitation, issued beyond the time provided u/s 149 of the Act.

4. The appellant submits that after the introduction of faceless Assessment scheme, the JAO cannot issue notice under section 148A and notice under section 148.

5. The Appellant submits that even the notice u/s 142(1) has been issued by JAO which is against the provisions of Sec. 151A and 144B.

6. The appellant submits that she is not employed anywhere, has no business and there is no scope for her to make any earnings whether explained OR unexplained. The appellant submits that to make addition u/s 69A there should be a chance of earning and that chance should result in unexplained deposit.”

3. In ground no.3 the assessee challenged the validity of the notice issued u/sec.148 of the Income Tax Act [in short "the Act"], 1961 being barred by limitation provided u/sec.149 of the Act.

4. The assessee is an individual and has not filed any return of income for the year under consideration as assessee has claimed that assessee has no regular source of taxable income. The assessment was reopened by the Assessing Officer by issuing notice u/sec.148 of the Act dated 13.04.2022 on account of cash deposit in the bank account of the assessee, which reads as under:

GOVERNMENT OF INDIA

MINISTRY OF FINANCE

INCOME TAX DEPARTMENT

OFFICE OF THE INCOME TAX OFFICER

WARD 12(1), HYDERABAD

To,

SIRISHA THUMMURU

FLAT NO 102 PLOT NO 19 WHISPER WOODS BLOCK 1, JUBILEE ENCLAVE BESIDE HO MADHAPUR

HYDERABAD 500081, Andhra Pradesh

India

Notice under section 148 of the Income-tax Act, 1961

Sir/Madam/ M/s.

• I have the following information in your case or in the case of the person in respect of which you are assessable under the Income tax Act, 1961(here in after referred to as "the Act") for Assessment Year 2015-16

• information flagged by the risk management strategy formulated in this regard suggesting that income chargeable to tax has escaped assessment within the meaning of section 147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2022-23/1042730198(1) dated 13/04/2022 and annexed herewith for reference,

2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other, allowance or deduction for the Assessment Year 2015-16 and I, hereby, require you to furnish, within 30 days from service of this notice, a return in the prescribed form of the Assessment Year 2015-16.

3. This notice is being issued after obtaining the prior approval of the PCCIT, AP & TELANGANA accorded on date 13/04/2022 vide Reference No. 100000029607728.

JHANSI VENKATA LAKSHMI PANTHAKANI

WARD 12(1), HYDERABAD

4.1. The Assessing Officer then passed the re-assessment order dated 29.01.2024 which was challenged by the assessee before the learned CIT(A) but could not succeed.

5. We have heard the learned Authorised Representative of the Assessee as well as le