PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

ITA 1592/HYD/2025Status: DisposedITAT Hyderabad24 December 2025AY 2022-23Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)32 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 by the JAO, outside the faceless mechanism, was bad in law and illegal. Consequently, the assessment order was quashed for want of valid assumption of jurisdiction.

What were the facts?

The assessee's reassessment proceedings under Section 147 were initiated by the Jurisdictional Assessing Officer (JAO) outside the faceless mechanism. The assessee argued that the notice under Section 148 was invalid as it was not issued in a faceless manner as per the prevailing schemes.

What were the issues?

The primary issue was the validity of reassessment proceedings initiated through a notice issued by the JAO, rather than through the prescribed faceless mechanism.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144(b),Section 151A

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Cases cited in this judgment(14)Show list

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Income Tax Appellate Tribunal, Hyderabad ‘SMC’ Bench, Hyderabad

For Appellant: Shri T. Venkanna, Sr. AR

Heard together (2 matters)

I.T.A. No.1591/Hyd/2025
I.T.A. No.1592/Hyd/2025

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PER RAVISH SOOD, JM: The captioned appeals filed by the assessee are directed against the respective orders passed by the Commissioner of Income Tax

The order continues below.

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