आदेश /O R D E R

PER S. R. RAGHUNATHA, AM :

The present appeal has been preferred by the Assessee against the order dated 21.12.2025 passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “the Ld. CIT(A)”], arising from the assessment order dated 19.03.2024 passed by the Assessing Officer, Assessment Unit, National Faceless Assessment Centre [hereinafter referred to as “the AO”], u/s.147 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the Assessment Year 2015-16.

The brief facts of the case, as borne out from the material available on record, are that the assessee is an individual and had not filed his return of income for the assessment year under consideration. Information received by the Department revealed that the assessee had deposited cash aggregating to Rs.2,09,00,000/- in his bank account and had also received contract receipts amounting to Rs.47,32,845/- during the relevant previous year.

Based on the aforesaid information, proceedings for reassessment were initiated by issuance of a show-cause notice u/s.148A(b) of the Act on 28.03.2022. Thereafter, an order u/s.148A(