Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 M/S Shivansh Infraestate Pvt. Ltd., Vs. The Deputy Commissioner Of 3Rd Floor, Block-A, Surajdeep Income Tax, Range-6, 3Rd Floor, Complex, 1-Jopling Road, 27/2, Raja Ram Mohan Rai Marg, Lucknow-226001 P.K. Complex, Lucknow Pan: Aaqcs5896P (Appellant) (Respondent) Assessee By: Sh. Shubham Rastogi, C.A. Revenue By: Sh. Neeraj Kumar, Cit Dr Date Of Hearing: 20.11.2025 Date Of Pronouncement: 13.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Passed Under Section 250 Of The Income Tax Act, 1961 On 18.01.2024 Wherein The Ld. Cit(A) Has Partly Allowed The Appeals Of The Assessee Against The Orders Of The Ld. Assessing Officer Dated 30.12.2017. The Grounds Of Appeal Are As Under:- “1- The Ld. Cit (A) Nfac Erred On Facts & In Law In Dismissing The Ground That Notice U/S 143(2) Was Issued By Ito-6(1) Lucknow On 01.04.2016 Without Appreciating That Jurisdiction Of Case Lies With Dcit, Range-6, Lucknow, Hence The Notice Issued By Ito-6(1) Is Without Jurisdiction & Invalid. Further, No Notice U/S 143(2) Has Been Issued By Jurisdictional Dcit, Range-Vi, Lucknow Within The Period As Per Section 143(2) Of L. T. Act. Hence The Present Assessment Is Invalid, Bad In Law & Liable To Be Quashed. 2- The Ld. C.I.T. (A) Upheld The Addition Without Appreciating That Ld. A. O. Rejected The Books Of Account & Instead Of Estimating The Net Profit, Additions Were Made On The Basis Of Same Books Of Account By Disallowing Expenses Under Different Heads Total Rs. 1,75,91,607/- & Addition U/S 68 R. W. S. 115Bbe Of I. T. Act For Rs. 1,32,78,833/- Which Is Contrary To The Provisions Of Law.

269T were applicable and he therefore, initiated penalty proceedings under section 271D of the Act. 6. The assessee was aggrieved at all these additions made by the ld. AO and accordingly filed an appeal before the NFAC. It challenged the notice issued under section 143(2) on the grounds that it had been issued by an officer not having jurisdiction