NOWROZ FALI JILLA,MUMBAI vs. ASSESSING OFFICER, MUMBAI

ITA 2643/MUM/2026Status: DisposedITAT Mumbai14 July 2026AY 2015-169 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice of reopening was issued by an officer without jurisdiction, as it should have been issued by the National Faceless Assessment Centre. Consequently, the entire reassessment proceeding and the assessment order were deemed void.

What were the facts?

The assessee did not file an original return for AY 2015-16. The AO initiated reassessment proceedings under Section 147 based on information about the sale of shares and an immovable property. The assessee responded by filing a return declaring a small income.

What were the issues?

The primary issue was the validity of the reassessment proceedings due to the notice being issued by a jurisdictional officer instead of the mandated Faceless Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 47

AI-generated summary — verify with the full judgment below

Before: SHRI AMIT SHUKLA & SHRI PRABHASH SHANKAR

For Appellant: Shri C.S. Pikle, AR
For Respondent: Shri Swapnil Choudhari, (Sr.DR.)
Hearing: 21.05.2026Pronounced: 14.07.2026

PER PRABHASH SHANKAR [A.M.] :- The present appeal emanating from the appellate order dated 09.02.2026 is preferred by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] pertaining to the assessment order passed u/s. 147 r.w.s. 144 of the Income-tax Act,

P a g e | 2 A.Y. 2015-16 Nowroz Fali Jilla 1961 [hereinafter referred to as “Act”] dated 21.03.2024 for the Assessment Year [A.Y.] 2015-16. 2. The grounds of appeal are as under: 1)The Learned CIT (Appeals) err

The order continues below.

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