DILEEP KUMAR SAKAMURI CHENCHU VENKATA,SRIKALAHASTI vs. INCOME-TAX OFFICER, WARD-1(3), TIRUPATI

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ITA 1615/HYD/2025Status: DisposedITAT Hyderabad10 December 2025Bench: us: "1. That on facts and circumstances of the case and in law, the Order under Section 147 rws 144 rws 144B of the Income-tax Act, 1961 (Act) as well as the Order under Section 250 of the Act is bad in law and in facts and circumstances of the case: 2. That on the facts and circumstances of the case and in law, the Ld. AO has erred in carrying out and the NFAC/CIT(A) have erred in confirming an addition on account of unexplained money amounting to INR 2,07,67,400 under Section 69A rws 11581 pages

AI SummaryAllowed

Facts

The assessee filed an appeal against the order passed by the CIT(Appeals) which arose from an order by the Assessing Officer (AO) under Section 147 read with Section 144B of the Income Tax Act, 1961. The AO had made additions for unexplained money and income from other sources based on cash deposits in bank accounts.

Held

The Tribunal held that the assessment order and notices were issued by the Jurisdictional Assessing Officer (JAO) outside the faceless mechanism, which is contrary to the current provisions and schemes introduced by the Finance Act, 2021. Therefore, the assessment was quashed for want of valid assumption of jurisdiction.

Key Issues

Whether the reassessment proceedings initiated and assessment order passed by the Jurisdictional Assessing Officer (JAO) outside the faceless mechanism, contrary to the e-assessment schemes, are legally sustainable?

Sections Cited

147, 144B, 250, 69A, 11588E, 23B, 234C, 148, 151A, 144, 130, 142, 148A

AI-generated summary — verify with the full judgment below

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

For Appellant: Shri Waseem UR Rehman, Sr. AR

आदेशक��त�ल�पअ�े�षत/ Copy of the order forwarded to:-