INCOME TAX OFFICER, WARD-8(1), HYDERABAD vs. DAGUMATI SWATHI, HYDERABAD
Facts
The Revenue appealed against the order of the CIT(A) which had quashed the reassessment proceedings. The AO had initiated reassessment under Section 147 based on substantial cash deposits by the assessee. The CIT(A) quashed the proceedings, holding that the notices were issued without jurisdiction after the introduction of the Faceless Assessment Scheme.
Held
The Tribunal held that the reassessment proceedings were initiated by the Jurisdictional Assessing Officer (JAO) outside the faceless mechanism, which is contrary to the 'Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022' and 'e-Assessment Scheme of Income Escaping Assessment Scheme, 2022'. The issue was squarely covered by the judgment of the Hon'ble High Court of Telangana, which held that only the Faceless Assessing Officer (FAO) can issue such notices. Thus, the reassessment proceedings were invalid and void.
Key Issues
Whether reassessment proceedings initiated by a Jurisdictional Assessing Officer (JAO) after the introduction of the Faceless Assessment Scheme are valid, or if they must be issued by the Faceless Assessing Officer (FAO) as per the prescribed scheme.
Sections Cited
Section 147, Section 144, Section 144B, Section 148, Section 148A, Section 149(1)(b), Section 142(1), Section 142(3), Section 151A
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad
आदेशक���त�ल�पअ�े�षत/ Copy of the order forwarded to:- 1. �नधा�रती/The : Dagumati Swathi, Flat No.101, Crown Residency, Puppalaguda, Rajendranagar, Hyderabad, Assessee Telangana-500089. 2. राज�व/ The Revenue : Income Tax Officer, Ward-8(1), Room No.907, 9th Floor, Signature Towers, Kondapur, Hyderabad, Telangana-500084. 3. The Principal Commissioner of Income Tax, Hyderabad. 4. �वभागीय��त�न�ध, आयकरअपील�यअ�धकरण /DR,ITAT, Hyderabad.
17 ITA No.1638/Hyd/2025 ITO VS DAGUMATI SWATHI 5. The Commissioner of Income Tax 6. गाड�फ़ाईल / Guard file
आदेशानुसार / BY ORDER
Sr. Private Secretary ITAT, Hyderabad.