CHITRAKOOT TRADELINE PRIVATE LIMITED,KOLKATA vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

ITA 193/KOL/2025Status: DisposedITAT Kolkata26 February 2026AY 2012-13Bench: SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessment order, framed by the National Faceless Assessment Centre, was without jurisdiction as it was issued prior to the notification conferring jurisdiction for such faceless assessments. The Tribunal found support in various judicial pronouncements that quashed similar assessments based on jurisdictional issues.

What were the facts?

The assessee is in appeal against an order confirming an addition of Rs. 2,95,60,000 made to its total income. The addition was for share capital and premium received, which the Assessing Officer (AO) treated as unexplained cash credits under Section 68 of the Income Tax Act, 1961. The assessee contended that the transactions were genuine and supported by documentation.

What were the issues?

Whether the assessment framed by the National Faceless Assessment Centre was without jurisdiction due to the timing of the notification conferring such powers.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 142(1),Section 68,Section 271(1)(c),Section 151A

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Income Tax Appellate Tribunal, “A” BENCH, KOLKATA

For Appellant: Shri Deep Agarwal &
For Respondent: Shri Santanu Ghosh, DR
Hearing: 22.01.2026Pronounced: 26.02.2026

Per Rajesh Kumar, AM:

This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 25.11.2024 for the AY 2012-13. 2. At the time of hearing, the assessee raised additional ground which is extracted below:

"1.That the assessment order passed under section 143(3) of the Income-tax Act, 1961 is bad in law and without juri iction and liable to be quashed, as all notices issued under section 142(1), the Show Cause Notice and the Assessment Order framed the basis of the impugned assessment were issued prior

The order continues below.

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