PRAKASH REDDY VATTI,HYDERABAD vs. ITO, WARD-11(1), HYDERABAD

ITA 1806/HYD/2025Status: DisposedITAT Hyderabad23 January 2026AY 2015-16Bench: SHRI VIJAY PAL RAO (Vice President)1 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 by the Jurisdictional Assessing Officer (JAO) without following the mandatory procedure for National Faceless Assessment rendered the proceedings invalid. Consequently, the reassessment order was also vitiated.

What were the facts?

The assessee's appeal challenges the reassessment proceedings initiated under Section 148A and notice under Section 148 for AY 2015-2016. The assessee argued that the reassessment was barred by limitation and that the reopening was based on unverified information from the 'Insight Portal'.

What were the issues?

The primary issues were the validity of the reassessment notice due to alleged limitation bar and procedural violations, including the failure to adhere to faceless assessment norms and the reliance on uncorroborated material.

Which sections of the Income-tax Act were involved?

Section 148A,Section 148,Section 149,Section 69A,Section 151A,Section 144B

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Income Tax Appellate Tribunal, Hyderabad ‘SMC’ Bench, Hyderabad

Before: SHRI VIJAY PAL RAO

Hearing: 15.01.2026

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 19.08.2025 of the learned CIT(A)-National Faceless Appeal Centre [in short “NFAC], Delhi, for the assessment year 2015-2016. 2 ITA.No.1806/Hyd./2025

2.

The Assessee has raised the following grounds in the instant appeal:

1.

That the learned Assessing Officer erred in initiating proceedings under Section 148A(b) and issuing notice under Section 148 dated 27.04.2022 without fulfilling the mandatory conditions prescribed under Sections 147, 148, 148A, and 149 of the Income Tax Act, 1961; the reassessment i

The order continues below.

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