आदेश / O R D E R

PER PADMAVATHY.S, A.M:

This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 13.02.2026 for Assessment Year (AY) 2015-16.

2. The assessee is an individual and did not file the return of income for the AY 2015-16. The A.O received information that the assessee is having substantial financial transactions in her bank account. Consequently, the A.O issued a notice u/s. 148(b) of the Act on 20.03.2022. The A.O subsequently passed an order u/s. 148A(d) of the Act and issued a notice u/s. 148 of the Act reopening the assessment on 04.04.2022. The A.O called on the assessee to furnish various details and completed the assessment assessing the income at Rs.24,27,367/-. On further appeal, the CIT(A) confirmed the addition/disallowances made by the A.O.

3. The Ld. Authorized Representative (AR) of the assessee submitted that if the legal contentions raised with regard to the notice u/s.148 of the Act being barred by limitation (ground No.5) is considered and adjudicated in favour of the assessee then