SATYANARAYANA KODURU,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-1, GUDIWADA

ITA 491/VIZ/2025Status: DisposedITAT Visakhapatnam05 December 2025AY 2016-17Bench: Shri Ravish Sood (Judicial Member), Shri Balakrishnan S. (Accountant Member)25 pages
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What did the Tribunal hold?

The Tribunal held that notices and orders issued by the JAO outside the faceless mechanism, as mandated by Section 144B and the E-Assessment Scheme, are bad in law. The JAO lacked jurisdiction to initiate these proceedings.

What were the facts?

The assessee's appeal challenges reassessment proceedings initiated by the Jurisdictional Assessing Officer (JAO) outside the faceless mechanism. The AO made additions for unexplained investments, stamp duty, cash deposits, salary, and interest.

What were the issues?

Whether reassessment proceedings initiated by the Jurisdictional Assessing Officer outside the faceless mechanism are valid. Whether the JAO had the jurisdiction to issue notices under Section 148A and 148.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 148,Section 148A,Section 151A,Section 69,Section 69A,Section 124

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Income Tax Appellate Tribunal, Visakhapatnam Bench, Visakhapatnam

Before: Shri Ravish Sood & Shri Balakrishnan S.

PER. RAVISH SOOD, JM :

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax, National Faceless Appeal Centre, Delhi, dated 01/07/2025, which in turn arises from the order passed by the Assessing Officer (for short, ”AO”) under Section 147 r.w.s 144 r.w.s 144B of the Income-tax Act, 1961 (for short, “Act”), dated 10/01/2024, for the Assessment Year 2016-17. The assessee has 2 “1) That on the facts and circumstances of

The order continues below.

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