PITTI HOLDINGS PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(1), HYDERABAD

ITA 450/HYD/2025Status: DisposedITAT Hyderabad08 October 2025AY 2018-19Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MADHUSUDAN SAWDIA (Accountant Member)41 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment notice issued by the jurisdictional Assessing Officer was invalid. Furthermore, since no additions were made on the primary issue for reopening, the reassessment order was not valid.

What were the facts?

The assessee's appeal challenges the validity of a reassessment notice issued by a jurisdictional Assessing Officer instead of a faceless Assessing Officer. The Assessing Officer also did not make any additions on the specific issue for which the assessment was reopened.

What were the issues?

The primary issues were the validity of reassessment notices issued by a non-faceless AO and whether an AO can make additions on issues other than those forming the basis of reopening when no additions are made on the original issue.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 147

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

Before: SHRI VIJAY PAL RAO & SHRI MADHUSUDAN SAWDIA

Hearing: 09/09/2025

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the assessee is directed against the order dated 16.01.2025 of Learned Commissioner of Income Tax (Appeals) for the Asst. Year 2018-19. 2. The assessee has raised the following grounds of appeal :

3.

Ground No.1 is general in nature and does not require any specific adjudication.

4.

Ground Nos.2 & 3 are regarding validity of Notice issued u/s.148 of the Income Tax Act, 1961 (“the Act”) by the juri ictional Assessing Offic

The order continues below.

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