IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2019-20 Ashu Aggarwal Vs. Income Tax Officer, Bhagwan Ganj Mandi, Circle-2(1)(1)

Modi Nagar S.O. Modinagar Ghaziabad Ghaziabad- 201204 Uttar Pradesh PAN: AFLPA4548R (Appellant) (Respondent)

Assessee by Ms. Shivani, Adv.

Department by Sh. Manoj Kuamr, Sr. DR (VC)

Date of hearing 22.04.2026 Date of pronouncement 22.04.2026 ORDER This assessee’s appeal for assessment year 2019-20, 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/250/2025-26/1080923882(1), dated 19.09.2025 involving proceedings under section 147 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 section 148A(d) proceedings herein itself initiated vide notice dated 26.04.2023 in assessment year 2019-20. This is for the precise reason that the learned Assessing Authority had obtained the necessary approval from the