VIJAY KUMAR PATIL,HYDERABAD vs. INCOME TAX OFFICER, WARD-7(1), HYDERABAD

ITA 1328/HYD/2025Status: DisposedITAT Hyderabad24 December 2025AY 2017-2018Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)26 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that notices issued by the JAO under Section 148 after the CBDT notification were invalid. Consequently, the reassessment order was quashed, and the appeal was allowed on this legal ground.

What were the facts?

The assessee challenged reassessment proceedings initiated by the Jurisdictional Assessing Officer (JAO) instead of the Faceless Assessing Officer (FAO). The JAO issued notices under sections 148A and 148, which the assessee argued were invalid as per CBDT notifications mandating faceless assessment units. The lower appellate authority had dismissed the assessee's appeal.

What were the issues?

Whether notices issued by the Jurisdictional Assessing Officer under Section 148 are invalid when faceless assessment procedures are mandated by CBDT notifications. Whether the assessee is barred from raising jurisdictional objections after the stipulated time.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151A

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Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 16/12/2025

Per Madhusudan Sawdia, A.M.:

This appeal is filed by Shri Vijay Kumar Patil (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 30.06.2025 for the A.Y. 2017-18. 2. The assessee has raised the following grounds of appeal:

ITA No 1328 of 2025 Vijay Kumar Patil

3.

The assessee has also raised the following additional ground of appeal: “The notices and orders issued by the Juri ictional

The order continues below.

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