PATTAVEETTIL PARAMESWAR RAMACHANDRAN,ERNAKULAM vs. ITO,WARD 2, ERNAKULAM

This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi [“CIT(A)” in short] dated 11.04.2025 for Assessment Year (AY) 2016-17.

At the outset, the ld. AR submitted that that although the ld. CIT(A) has set aside the order of AO and restore the same back to the file of the AO with a direction to the AO to frame the assessment order afresh after adequate opportunity to the assessee, however the ld. CIT(A) has not considered the CBDT Notification dated

Per contra, the Ld. DR relied upon the order of the lower authorities.

We have heard the rival submissions and perused the record. We find that the assessee has raised the issue before the ld.CIT(A) relating to the the CBDT issued a Notification dated 29.03.2022 formulating “the e-assessment of income assessment Scheme, 2022”. The Scheme provides that (a) the assessment/re-assessment are re-computation u/s.147 of the Act and (b) issuance of notice u/s.148 of the Act shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred u/s.148 of the Act for issuance of notice and in a faceless manner to the extent providing in Section 144B of the Act with reference to making assessment/re-assessment of total income or loss of the assessee however, not disposed by him. Therefore, in the light of above factual matrix, we set aside the impugned order and restored back the appeal to the file the ld. CIT(A) to decide the issue whether the jurisdictional assessing officer (JAO) can issue notice u/s147 after 29.03.2022 in light of the aforesaid circular. Needless to say, the ld. CIT(A) will provide adequate opportunity to the assessee in the appeal proceedings.