ORDER

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals)-10, Hyderabad, dated 03/02/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144 r.w.s of the Income Tax Act, 1961 (for short, “the Act”), dated04/12/2024 for the Assessment Year (AY) 2015-16. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

“1. The Order of the Learned Commissioner of Income Tax (Appeals) is against the law, weight of evidence and probabilities of the case.

2. The assessment order dated 04.12.2024 passed by the Assessing Officer under section 147 r.w.s. 144 of the Act is barred by limitation and non-est in law, as the same is passed beyond the period of ONE YEAR from the end of the financial year in which the notice under section 148 of the Act was issued.

3. That the learned Assessing Officer erred in law in issuing the notice under section 148 of the Income tax Act, 1961, beyond the prescribed time limit as stipulated under section 149. The Impugned notice has been issued after the expiry of three years from th