BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

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ITA 1363/HYD/2025Status: DisposedITAT Hyderabad21 January 2026AY 2019-20Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the notice under Section 148 and the consequential assessment order were invalid because they were issued by the Jurisdictional Assessing Officer (JAO) outside the faceless mechanism, contrary to Section 151A and the E-Assessment Scheme. Therefore, the assessment was quashed for want of valid assumption of jurisdiction.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under Section 147 of the Income Tax Act, 1961, for AY 2019-20. The AO issued a notice under Section 148, and the assessee filed a return. The AO, finding the expenses unsubstantiated, estimated the income and passed an assessment order.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated by the AO outside the prescribed faceless assessment mechanism. The Tribunal also considered whether the assessment order was sustainable without proper substantiation of expenses.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151A,Section 144B,Section 145

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

For Appellant: Shri AP Babu, Sr. AR

आदेशक���त�ल�पअ�े�षत/ Copy of the order forwarded to:- 1. �नधा�रती/The : Bilwa Infrastructure Limited C/o. P. Murali and Co., Chartered Accountants, 6-3-655/2/3, Somajiguda, Assessee Hyderabad, Telangana-500082. 2. राज�व/ The Revenue : Income Tax Officer, Ward-1(1), Hyderabad. 3. The Principal Commissioner of Income Tax, Hyderabad. 4. �वभागीय��त�न�ध, आयकरअपील�यअ�धकरण /DR,ITAT, Hyderabad. 5. The Commissioner of Income Tax 6. गाड�फ़ाईल / Guard file

आदेशानुसार / BY ORDER

Sr. Private Secretary ITAT, Hyderabad.

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