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), National Faceless Appeal Centre, Delhi (for short, “CIT(A)”), dated 06/10/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 25/11/2023. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

“1. The order of the Ld. CIT(A) is bad in both law and on facts of the case.

2. On the facts and circumstances of the case, the order u/s 148A(d) dated 05.04.2022 and notice issued u/s 148 dated 06.04.2022 for AY 2015-16 are bad in law as the same were issued in contravention to provisions of section 149 of the Act and hence the subsequent proceedings and the assessment order dated 25.11.2023 are to be held as invalid.

3. The order u/s 148A(d) dated 05.04.2022 and notice u/s 148 of the Act dated 06.04.2022 for A.Y. 2015-16 are bad in law as the same were issued in contravention to provisions of Section 151A of the Act. The Jurisdictional Assessing Officer (JAO) has no authority to