YADIKI PACS,ANANTAPUR vs. INCOME TAX OFFICER, WARD-1, ANANTAPUR

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ITA 926/HYD/2025Status: DisposedITAT Hyderabad09 January 2026Bench: the Andhra Pradesh High Court against the Order of the Chief Commissioner of Income Tax, Hyderabad rejecting the appellant's application filed u/s 119(2)(b) of the Act to condone the delay in filing the Income Tax Return for the subject AY 2019-20 is pending for disposal as on date. 7. For that the Learned Commissioner of Income Tax (Appeals) had erred in confirming the levy of interest u/s 234A of the Act in consequence to the above." 31 pages

AI SummaryAllowed

Facts

The assessee, a Trust, failed to file its return of income for AY 2019-20. Reassessment proceedings were initiated based on cash deposits of Rs. 4,08,95,292/-, which remained unexplained. The Assessing Officer disallowed a deduction of Rs. 1,08,08,087/- claimed under Section 80P.

Held

The Tribunal held that the notice under Section 148 was issued by the Jurisdictional Assessing Officer and not the Faceless Assessing Officer, which violates the Faceless Assessment Scheme. Therefore, the assessment order passed consequently is without jurisdiction and liable to be quashed.

Key Issues

Whether the reassessment proceedings initiated by the Jurisdictional Assessing Officer, instead of the Faceless Assessing Officer, are valid and whether the disallowance of deduction under Section 80P is justified.

Sections Cited

139, 148A, 148, 147, 144B, 80P, 80AC, 139(1), 124(3), 151A, 142(1), 143(2), 234A, 119(2)(b)

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Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:- 1. निर्धाररती/The Assessee : Yadiki PACS, Yadiki Vil Pa, Yadiki Mandal, Anantapur – 515400, Andhra Pradesh, India - 515400. 2. रधजस्व/ The Revenue : The Income Tax Officer, Ward – 1, Anantapur. 3. The Principal Commissioner of Income Tax, Kurnool. 4. नवभधगीयप्रनतनिनर्, आयकर अपीलीय अनर्करण, हैदरधबधद / DR, ITAT, Hyderabad 5. गधर्ाफ़धईल / Guard file

आदेशधिुसधर / BY ORDER

Sr. Private Secretary ITAT, Hyderabad