GATTULA LAKSHMI MADHAVI,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

ITA 387/VIZ/2025Status: DisposedITAT Visakhapatnam10 December 2025AY 2018-19Bench: Shri Manjunatha G. (Accountant Member), Shri Ravish Sood (Judicial Member)30 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Act was invalid as it was issued by the JAO outside the faceless mechanism, contravening Section 151A of the Act. Consequently, the assessment and penalties were quashed.

What were the facts?

The assessee acquired immovable properties and was engaged in construction business. She did not file her return of income for AY 2018-19, leading to reassessment proceedings. The Assessing Officer (AO) made additions for unexplained investment and estimated business income.

What were the issues?

Whether the notice issued under Section 148 of the Income Tax Act, 1961, was validly issued in accordance with the faceless assessment scheme. Whether the additions made by the AO for unexplained investment and estimated business income were justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 271AAC(1),Section 270A,Section 69,Section 44AD,Section 148,Section 148A,Section 151A,Section 144B

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Income Tax Appellate Tribunal, Visakhapatnam Bench, Visakhapatnam

Before: Shri Manjunatha G. & Shri Ravish Sood

PER RAVISH SOOD, JM: The captioned appeals filed by the assessee are against the respective orders passed by the Commissioner of Income Tax (Appeals), Visakhapatnam-3, dated 21/03/2025, 24/03/2025 and 16/04/2025, which in turn arises from the respective orders passed by the Assessing Officer (for short, “AO”) under section 147 of the Income Tax Act, 1961 (for short, "the Act”), dated 27/03/2023; under section 271AAC(1) of the Act, dated 21/08/2023; and under section 270A of the Act, dated 21/08/2023 for Assessmen

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