PER PAWAN SINGH, JUDICIAL MEMBER:

1. This appeal by assessee is directed against the order of Ld. CIT(A) / NFAC dated 31.10.2025 for assessment year (A.Y.) 2016-17. The assessee has raised following grounds of appeal;

i. On the facts and circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeals) erred in appreciating that the notice u/s 148 and order u/s 148A(d) needs to be issued by Faceless Assessing Officer. However, in the current appeal the same has been issued by the Jurisdictional Assessing Officer and hence thus the notice u/s 148 and the order u/s 148A(d) are bad in law and the whole proceeding needs to be quashed.

ii. On facts and in circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeals) erred in upholding the issuance of notice u/s 148 dated 28.03.2023 as the same was without jurisdiction and barred by limitation of time, thereby rendering the assessment order passed by the Learned Assessing Officer as invalid and bad in law.

iii. On facts and in circumstances of the case, th