O R D E R

PER SANDEEP SINGH KARHAIL, J.M.

The assessee has filed the present appeal against the impugned order dated 13.11.2025 passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2015-16.

2. In this appeal, the assessee has raised the following grounds: -

“1. Notice u/s 148 of the Act dated 28.04.2022 is barred by limitation.

2. The notice u/s 148 is bad in law and without jurisdiction as the jurisdictional requirement of section 147 to 151A of the Act.

3. The notice u/s 148 of the Act is without jurisdiction and bad in law, as the same has been issued by the Jurisdictional Assessing Officer who has no jurisdiction.

4. The Assessment order passed u/s 147 r.w.s 144B of the Act dated 18.03.2024 is bad in law. Therefore, should be set aside.

5. The Ld. CIT(A), NFAC has erred in confirming the addition of Rs. 8,49,999/- made by the Ld.AO, in respect of capital gains by not allowing deduction u/s 54 of the Act.

6. The Ld. CIT(A), NFAC has erred in confirming the reassessment proceedings and upholding the order u/s 147 r.w.s 144B of the Act