ORDER

PER: SUNIL KUMAR SINGH, JM.

This appeal has been preferred against the impugned order dated 19.11.2025 passed in Appeal no. NFAC/2015-16/10117631 by the Ld. Commissioner of Income tax, (Appeals)/ NFAC Delhi,[hereinafter referred to as the “CIT(A)”] u/s. 250 of the Income tax Act, 1961 [hereinafter referred to as "Act"] for the Assessment year A.Y. 2016-17, wherein learned CIT(A) has dismissed assessee’s appeal.

2. The brief facts of the case are that the assessee filed return of income on 12.07.2016, declaring total income of Rs. 3,50,650/- on presumptive basis of gross receipts of Rs. 62,58,060/-. Department received an information from investigation wing that assessee incurred expenditure of Rs. 2,13,000/- on education of daughter. Further that the assessee had credits of Rs. 2,70,12,301/- in his bank accounts. Assessing officer, after recording reasons to believe and after obtaining sanction from the competent authority, issued notice u/s. 148 of the Act on 31.03.2021. Assessee filed belated return on 28.01.2022 in response to notice u/.s 148 of the Act, which was treated as non-est and the notice u/s. 143(2) was not issued accordingly. Assessee’s objections against the no