CHANDINI DUVVURI,HYDERABAD vs. ITO (INT TAXN)-1, HYDERABAD

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ITA 1432/HYD/2025Status: DisposedITAT Hyderabad12 December 2025AY 2015-16Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)12 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued by the Jurisdictional Assessing Officer (JAO) under Section 148 of the Act after 29.03.2022 is without jurisdiction and cannot be sustained, following decisions of the Telangana High Court. Therefore, the assessment order passed by the A.O. under Section 147 r.w.s. 144, consequent to the invalid notice, was quashed. Liberty was granted to both parties to revive the appeal if the pending Supreme Court decision on the matter requires it.

What were the facts?

The assessee, a non-resident, did not file an income tax return for AY 2015-16. Information from the Risk Management Strategy indicated significant financial transactions. Consequently, the A.O. initiated reassessment proceedings, treated time deposits as unexplained investment and interest as income, completing an ex-parte assessment under Section 144 r.w.s. 147 due to the assessee's non-compliance. The CIT(A) set aside this assessment and restored the matter to the A.O. for fresh assessment, which the assessee challenged, arguing the original notice under Section 148 was invalid.

What were the issues?

Whether the reassessment notice issued under Section 148 by the Jurisdictional Assessing Officer after 29.03.2022 is valid, given the introduction of the Faceless Assessment Scheme and precedents from the jurisdictional High Court.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 144,Section 139(1),Section 142(1),Section 69,Section 115BBE,Section 194A,Section 195,Section 271(1)(c),Section 151A,Section 144B,Section 251

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Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad

For Appellant: Shri Ashuthosh Pradhan

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-

1. 1. निर्धाररती/The Assessee : Chandini Duvvuri, Plot No.161, Defence Colony, Tirumalagiri, Sainikpuri, Hyderabad, Telangana – 500094. 2. रधजस्व/ The Revenue : The Income Tax Officer (International Taxation) – 1, Basheerbagh, Hyderabad.

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