SATAVAHANA UNIVERSITY,KARIMNAGAR vs. INCOME TAX OFFICER, WARD-2, KARIMNAGAR

ITA 1525/HYD/2025Status: DisposedITAT Hyderabad10 December 2025AY 2018-2019Bench: Shri Manjunatha G. (Accountant Member), Shri Ravish Sood (Judicial Member)33 pages
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What did the Tribunal hold?

The Income Tax Appellate Tribunal (ITAT) observed that the orders under Section 148A(d) and notices under Section 148 of the Act for all assessment years were issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO). Following the Hon'ble High Court of Telangana's judgment in Kankanala Ravindra Reddy Vs. ITO, the ITAT held that the assessment proceedings initiated by the JAO outside the faceless mechanism were illegal, constituting an invalid assumption of jurisdiction.

What were the facts?

Satavahana University (assessee) did not file income returns for AY 2016-17, 2018-19, and 2019-20, despite making substantial financial transactions including large time and cash deposits. The Assessing Officer (AO) reopened these cases based on RMS information, treating the unexplained deposits and interest income as additions under Sections 69/69A/115BBE of the Income Tax Act, 1961, and denying Section 10(23C) exemption. The CIT(A) upheld the AO's orders.

What were the issues?

Whether assessment proceedings initiated by the Jurisdictional Assessing Officer (JAO) under Sections 147/148/148A are valid when the "Faceless Jurisdiction of Income Tax Authorities Scheme, 2022" mandates such actions by a Faceless Assessing Officer (FAO).

Which sections of the Income-tax Act were involved?

Section 10(23C),Section 69,Section 69A,Section 115BBE,Section 139,Section 147,Section 148,Section 148A,Section 144B,Section 151A,Section 250

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Cases cited in this judgment(3)Show list

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Heard together (3 matters)

ITA No.1524/Hyd/2025
ITA No.1525/Hyd/2025
ITA No.1526/Hyd/2025

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आयकर अपीलीय अिधकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad Before Shri Manjunatha G., Accountant Member and Shri Ravish Sood, Judicial Member आ.अपी.सं /ITA No.1524/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17)

Ward-2, Karimnagar. PAN: AAAJS4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee by: Shri E. Phalguna Kumar, CA राज" व "ारा/Revenue by: Dr. Narendra Kumar Naik, CIT-DR आ.अपी.सं /ITA No.1525/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19)

Ward-2, Karimnagar. PAN: AAAJS4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee by: Shri E. Phalguna Kumar, CA राज" व "ारा/Revenue by: Dr. Narendra Kumar Naik, CIT-DR आ.अपी.सं /ITA No.1526/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20)

Ward-2, Karimnagar. PAN: AAAJS4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee by: Shri E. Phalguna Kumar, CA राज" व "ारा/Revenue by: Dr. Sachin Kumar, Sr. AR सुनवाई की तारीख/Date of Hearing: 13/11/2025 घोषणा की तारीख/Date of 10/12/2025 Pronouncement: Satavahana University

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