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“Section 124(3)(a)”

Section References (mined)Section 124Section 124(3)(a)106 judgments

The decision most relied on for Section 124(3)(a) is CIT v. S.G. Pgnatale (124 ITR 391), cited in 181 judgments on BharatTax.

Leading authorities on Section 124(3)(a)

CIT v. S.G. Pgnatale
124 ITR 391 · 1980 · High Court
181
citing judgments

An Explanation to Section 9(1)(ii) of the Income Tax Act that widens the scope of the provision, rather than merely clarifying it, cannot be applied retrospectively to assessment periods prior to its effective date. Assessments must be made according to the law in force at the relevant time.

Pr. CIT v. Golden Peace Hotels and Resorts (P) Ltd.
124 Taxmann.com 249 · 2021 · Supreme Court
105
citing judgments

A penalty levied under Section 271(1)(c) is not sustainable if the notice issued under Section 274 fails to specifically mention whether the charge relates to concealment of income or furnishing inaccurate particulars of income. The Assessing Officer must specify the exact charge for the penalty to be valid.

CIT v. NHK Japan Broadcasting Corporation
305 ITR 137 · 2008 · High Court
96
citing judgments

When no specific statutory period of limitation exists, proceedings under Section 201(1) and 201(1A) of the Income-tax Act, particularly for payments to non-residents, must be initiated within a reasonable period of four years. This limitation also applies to consequential penalty proceedings under Section 271C.

CIT v. Piara Singh
124 ITR 40 · 1980 · Supreme Court
95
citing judgments

When dealing with unaccounted transactions of purchase and sale, including those from an illegal business, only the profit or income earned from such sales can be assessed as undisclosed income and subjected to tax, not the entire sale proceeds.

Commissioner of Income-tax v. Ramesh D. Patel
362 ITR 492 · 2014 · High Court
91
citing judgments

Section 124(3) of the Income-tax Act, which restricts an assessee from objecting to an Assessing Officer's jurisdiction, applies only to disputes concerning territorial jurisdiction as conferred by Section 120(1) or (2). It does not apply to objections regarding the Assessing Officer's inherent jurisdiction to frame an assessment.

Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal
241 ITR 124 · 2000 · High Court
89
citing judgments

A penalty for concealment of income cannot be levied if an assessee files a revised return to buy peace and avoid litigation, and the revenue accepts this without objection.

Abhishek Jain v. ITO
94 Taxmann.com 355 · 2018 · High Court
89
citing judgments

An assessee cannot challenge the jurisdiction of the Assessing Officer if an objection is not filed within the prescribed one-month period from the date of receiving a notice. Failure to raise a timely objection under Section 124 before the AO waives the right to dispute jurisdiction later.

(i) CIT v. Focus Exports (P.) Ltd.
51 Taxmann.com 46 · 2014 · High Court
81
citing judgments

An addition under Section 68 for cash credits or share application money is not permissible if the assessee satisfactorily explains the identity and creditworthiness of the investor and the genuineness of the transaction.

Judgments citing Section 124(3)(a)

Sadhika Ganni, Rajahmundry vs. The Deputy Commissioner of Income Tax, Circle - 2, Rajahmundry

ITA 205/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam29 May 2026AY 2017-18

Bench: Us:

Section 127Section 143(2)Section 143(3)Section 263

Rajamahendravaram, within the statutory period of one month from the date of service of receipt of the notice as provided under Section 124(3)(a) of the Act, therefore, he was thereafter debarred from subsequently calling in question the validity of the jurisdiction assumed by the A.O for framing ... assessee had participated pursuant to the notice issued under section 142(1) and had not questioned the jurisdiction of the Assessing Officer. Section 124(3)(a) precludes the assessee from questioning the jurisdiction of the Assessing Officer, if he does not do so within 30 days of receipt of notice

Gurgaon One Resident Welfare Association, Gurgaon vs. ITO-Ward 1(5), Gurgaon

In the result appeal of the assessee is allowed

ITA 4145/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarita No.4145/Del/2025 (Assessment Year 2017-18) Gurgaon One Resident Welfare Income Tax Officer, Association, Ward-1(5), Gurgaon. Sector-22, Mullahera, Vs. Old Delhi Gurgaon Road, Gurgaon-122015, Haryana. Pan-Aaaag5591K (Appellant) (Respondent) Assessee By Shri M.R. Sahu, Ca Shri Manish Gupta, Sr. Dr. Department By Date Of Hearing 09.03.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeals Filed By The Assessee Are Against Orders Dated 13.06.2025 Of The Learned Commissioner Of Income Tax (Appeals)-Mumbai [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Orders Dated 28.12.2018 & 13.11.2019 Of Ld. Assessing Officer, Ward-1(5), Gurgaon For Assessment Years 2016-17 & 2017-18 Respectively. Gurgaon One Resident Welfare Association Vs. Ito

Section 124(3)(a)Section 142(1)Section 143(2)Section 250Section 57

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

Gurgaon One Resident Welfare Association, Gurgaon vs. ITO-Ward 1(5)-Gurgaon, Gurgaon

In the result appeal of the assessee is allowed

ITA 4144/DEL/2025[2016-17]Status: DisposedITAT Delhi13 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarita No.4145/Del/2025 (Assessment Year 2017-18) Gurgaon One Resident Welfare Income Tax Officer, Association, Ward-1(5), Gurgaon. Sector-22, Mullahera, Vs. Old Delhi Gurgaon Road, Gurgaon-122015, Haryana. Pan-Aaaag5591K (Appellant) (Respondent) Assessee By Shri M.R. Sahu, Ca Shri Manish Gupta, Sr. Dr. Department By Date Of Hearing 09.03.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeals Filed By The Assessee Are Against Orders Dated 13.06.2025 Of The Learned Commissioner Of Income Tax (Appeals)-Mumbai [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Orders Dated 28.12.2018 & 13.11.2019 Of Ld. Assessing Officer, Ward-1(5), Gurgaon For Assessment Years 2016-17 & 2017-18 Respectively. Gurgaon One Resident Welfare Association Vs. Ito

Section 124(3)(a)Section 142(1)Section 143(2)Section 250Section 57

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

Income Tax Officer, Non Corporate Ward 22(1), Chennai vs. Ezhumalai, Thirukazhukundram

ITA 4108/CHNY/2025[2019-20]Status: DisposedITAT Chennai12 Mar 2026AY 2019-20

Bench: Shri George George K, Vice- & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.4108/Chny/2025 िनधा"रण वष" / Assessment Year: 2019-20 Income Tax Officer, V Ezhumalai, Non Corporate Ward- S 1123, Ponpatharkoodam, 22(1), Tambaram Gangai Amman Koil Street, Thirukazhukundram, Chengalpattu – 603405 Pan: Acipe8113C Appellant/ Revenue Respondent / Assessee Assessee By None Revenue By Ms. V Aswathy – Jcit Date Of Hearing 18/02/2026 Date Of Pronouncement 12/03/2026 आदेश/ Order Per Inturi Rama Rao, Am : This Appeal Filed By The Revenue Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi

Section 120Section 143(2)Section 144Section 147Section 148Section 148ASection 250

आयकर अपीलीय अिधकरण ”डी” "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL CHENNAI BENCHES “D” :: CHENNAI BEFORE SHRI

Jayesh Kanungo HUF, Khetwadi, Mumbai vs. ITO-19(2)(1), Parel, Mumbai

In the result, the appeal of the assessee is allowed

ITA 6855/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Mar 2026AY 2014-15

Bench: Shri. Bijayananda Prusethjayesh Kanungo Huf Ito -19(2)(1), Mumbai 203, Rajgiri Apartment, A Wing, Vs. Piramal Chambers, Lalbaug, 13Thkhetwadi Back Road, Mumbai Parel Mumbai 400012 400004 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabhj8492E (Appellant) (Respondent)

For Appellant: Shri. Rajkumar Singh a/w. Ms. Asifa KhanFor Respondent: Shri. Nakul Agrawal Sr. DR
Section 10(38)Section 127Section 143(2)Section 143(3)Section 148Section 250Section 68Section 69C

assessee had participated pursuant to the notice issued under Section 142 (1) and had not questioned the jurisdiction of the assessing officer. Section 124(3)(a) of the Income Tax Act precludes the assessee from 30 days of receipt of notice under Section 142(1). In the present case

Income Tax Officer, Ward-1, Gudiwada vs. Chagantipadu Primary Agricultural Co-Operative Credit Society Limited Noh957, Chagantipadu Village

In the result, the appeal by the Revenue and the cross objection by the

ITA 641/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam06 Feb 2026AY 2018-19

Bench: Shri Sandeep Singh Karhail, Hon’Ble

Section 147Section 148Section 250Section 69A

duly followed while issuing notice under section 148 of the Act and while completing the assessment. By referring to the provisions of section 124(3) of the Act, the Ld. DR submitted that any objection against the jurisdiction of the Assessing Officer can be raised only within the period ... submitted that the Hon’ble Supreme Court in the aforesaid decision has held that, as per the mandate of section 124(3) of the Act, the assessee is precluded from questioning the jurisdiction of the Assessing Officer if he does not do so within a period of 30 days

Jagdish Kumar Yadav, Durg vs. ITO, Ward-1(1), Bhilai

In the result, appeal of the assessee is allowed

ITA 593/RPR/2025[2010-11]Status: DisposedITAT Raipur04 Feb 2026AY 2010-11

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.593/Rpr/2025 "नधा"रण वष" /Assessment Year : 2010-11 Jagdish Kumar Yadav Near Boudh Vihar Near To S.V Public School, Shankar Nagar, Durg-491 001 (C.G.) Pan: Aakpy0660J .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bhilai (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 127Section 142(1)Section 143(2)Section 143(3)Section 148

eyes of law. 3. Per contra, the Ld. Sr. Departmental Representative (for short ‘DR’) vehemently submitted that as per Section 124(3)(a) of the Act, if the assessee had any objection regarding the jurisdiction of the Assessing Officer, then the same could have been raised within one month from ... assessee had participated pursuant to the notice issued under Section 142(1) and had not questioned the jurisdiction of the assessing officer, then Section 124(3)(a) of the Income Tax Act precludes the assessee from questioning the jurisdiction of the assessing officer, if he does not do so within

Venkata Sujatha Chruvupalli, Hyderabad vs. Income Tax Officer, Ward-9(3), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 233/HYD/2025[2017-18]Status: DisposedITAT Hyderabad04 Feb 2026AY 2017-18
For Appellant: Shri G. Srinivasa Rao, CAFor Respondent: : Shri Karthik Manickam, SR-DR
Section 124(3)(a)Section 127(2)Section 129Section 143(2)

issued by the non-jurisdictional Assessing Officer but not by the Jurisdictional Assessing Officer (JAO), the provisions of section 124(3)(a) or 127(4) does not come into play and therefore the impugned assessment order is invalid due to want of assuming valid jurisdiction ... within the jurisdiction of Respondent No. 2 and hence notice was sent by the Office of Respondent No. 2. He further referred to Section 124(3)(a) of the Act and contended that the Petitioner ought to have questioned the jurisdiction of Respondent No. 2 immediately after receiving the notice

Kunshan Q Tech Microelectronics (India) Pvt. Ltd., Uttar Pradesh vs. DCIT, Central Circle-30, Delhi

ITA 5356/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Jan 2026AY 2021-22
Section 132Section 143(3)Section 144CSection 144C(5)Section 148Section 153

conferring power upon Addl. CIT. Therefore, this Judgment would not support the case of the Revenue. It maybe noted further that provisions of Section 124(3) of the LT. Act would not be applicable in the case of the assessee because Addl. CIT, Range-23, New Delhi did not have ... vide order dated 20.03.2024 has dismissed the appeal of the Revenue by observing as under: "6. In our considered opinion, the provisions of Section 124(3) of the Act and the questions surrounding that provision would have warranted further consideration, provided the appellant had been able to establish that

Veerprabhu Auto Pvt. Ltd., Kolkata vs. A.C.I.T., CC - 2(4), Kol, Kolkata

In the result, the appeal filed by the assessee is dismissed

ITA 1218/KOL/2024[2016-2017]Status: DisposedITAT Kolkata12 Jan 2026AY 2016-2017

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 132Section 143(3)Section 250

sections 124 (4) and 124 (2) have been rendered redundant in this case and the present case is squarely hit by provisions of section 124(3)(a) and 124(3)(c) as well, whereby the assessee has forgone its entitlement to question the jurisdiction

Income Tax Officer, Ward - 2 (1), Varanasi vs. Prominent Datamatics Marketing Pvt. Ltd., Varanasi

ITA 135/VNS/2020[2017-2018]Status: DisposedITAT Varanasi05 Jan 2026AY 2017-2018

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 124(1)(a)Section 124(2)Section 124(3)(a)Section 250(1)Section 255(4)Section 69A

facts and circumstances of the case, the assessee can question the jurisdiction of the AO, in view of the provisions of section 124(3)(a) of the Income Tax Act or not ? 3. Whether in the facts and circumstances of the case, ITO ward 5(2), Kolkata was having jurisdiction ... facts and circumstances of the case, the assessee can question the jurisdiction of the AO, in view of the provisions of section 124(3)(a) of the Income Tax Act ornot? 3. Whether in the facts and circumstances of the case, ITO ward 5(2), Kolkata was having jurisdiction

Raghu Alekh Barli, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 915/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

submitted that the Hon’ble Apex Court, in the said decision, has categorically held that, in view of the mandate of Section 124(3) of the Act, an assessee is precluded from assailing the jurisdiction of the Ld. AO if such objection is not raised within 30 days from ... precluded from assailing the same for the first time before the Tribunal. 16. Before proceeding further, it would be relevant to cull out Section 124(3) of the Act, which reads as under: "124 (1) xxxxxxxx (2) xxxxxxx (3) No person shall be entitled to call in question the jurisdiction

Bikaram Pushpender, Hyderabad vs. ITO, Ward-9(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 1606/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

submitted that the Hon’ble Apex Court, in the said decision, has categorically held that, in view of the mandate of Section 124(3) of the Act, an assessee is precluded from assailing the jurisdiction of the Ld. AO if such objection is not raised within 30 days from ... precluded from assailing the same for the first time before the Tribunal. 16. Before proceeding further, it would be relevant to cull out Section 124(3) of the Act, which reads as under: "124 (1) xxxxxxxx (2) xxxxxxx (3) No person shall be entitled to call in question the jurisdiction

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1592/HYD/2025[2022-23]Status: DisposedITAT Hyderabad24 Dec 2025AY 2022-23

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 132Section 147Section 148

submitted that the Hon’ble Apex Court in its aforesaid judgment had held that as per the mandate of Section 124(3) of the Act, an assessee is precluded from questioning the jurisdiction of the AO, if he does not do so within 30 days of receipt of notice ... submitted that in the present case, the assessee as required per the mandate of Section 124(3) of the Act, had within the prescribed time period not called in question the jurisdiction of the ACIT, Central Circle 1(1), Hyderabad, i.e., the JAO, who had issued Notice under Section

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1591/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21
Section 132Section 147Section 148

submitted that the Hon’ble Apex Court in its aforesaid judgment had held that as per the mandate of Section 124(3) of the Act, an assessee is precluded from questioning the jurisdiction of the AO, if he does not do so within 30 days of receipt of notice ... submitted that in the present case, the assessee as required per the mandate of Section 124(3) of the Act, had within the prescribed time period not called in question the jurisdiction of the ACIT, Central Circle 1(1), Hyderabad, i.e., the JAO, who had issued Notice under Section

Sanzyme Private Limited, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 1487/HYD/2025[2019-2020]Status: DisposedITAT Hyderabad24 Dec 2025AY 2019-2020

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

submitted that the Hon’ble Apex Court, in the said decision, has categorically held that, in view of the mandate of Section 124(3) of the Act, an assessee is precluded from assailing the jurisdiction of the Ld. AO if such objection is not raised within 30 days from ... precluded from assailing the same for the first time before the Tribunal. 16. Before proceeding further, it would be relevant to cull out Section 124(3) of the Act, which reads as under: "124 (1) xxxxxxxx (2) xxxxxxx (3) No person shall be entitled to call in question the jurisdiction

Vijay Kumar Patil, Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our above observation

ITA 1328/HYD/2025[2017-2018]Status: DisposedITAT Hyderabad24 Dec 2025AY 2017-2018

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1328/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Vijay Kumar Patil Vs. Income Tax Officer Hyderabad Ward 7(1) Pan:Aqopp2830M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sarang Shah राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 16/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: CA Sarang ShahFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 124Section 124(3)Section 147Section 148Section 148ASection 151A(1)

submitted that the Hon’ble Apex Court, in the said decision, has categorically held that, in view of the mandate of Section 124(3) of the Act, an assessee is precluded from assailing the jurisdiction of the Ld. AO if such objection is not raised within 30 Page ... precluded from assailing the same for the first time before the Tribunal. 16. Before proceeding further, it would be relevant to cull out Section 124(3) of the Act, which reads as under: "124 (1) xxxxxxxx (2) xxxxxxx (3) No person shall be entitled to call in question the jurisdiction

Lingamgunta Adilaxmi, Secunderabad vs. ITO., Ward-10(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 1317/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Dec 2025AY 2015-16

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

submitted that the Hon’ble Apex Court, in the said decision, has categorically held that, in view of the mandate of Section 124(3) of the Act, an assessee is precluded from assailing the jurisdiction of the Ld. AO if such objection is not raised within 30 days from ... precluded from assailing the same for the first time before the Tribunal. 16. Before proceeding further, it would be relevant to cull out Section 124(3) of the Act, which reads as under: "124 (1) xxxxxxxx (2) xxxxxxx (3) No person shall be entitled to call in question the jurisdiction

The Ookal Farmers Service Cooperative Society Limited, Warangal vs. ITO., Ward-1, Warangal

In the result, all three appeals of the assesssee, i

ITA 1145/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 80PSection 80P(2)(d)

submitted that the Hon’ble Apex Court in its aforesaid judgment had held that, as per the mandate of Section 124(3) of the Act, an assessee is precluded from questioning the jurisdiction of the AO if he does not do Society Limited VS. ITO so within 30 days ... receipt of notice. The Ld. Sr. DR submitted that in the present case, the assessee as required per the mandate of Section 124(3) of the Act, had within the prescribed period not called in question the jurisdiction of the ITO, Ward 1, Warangal, i.e., the JAO, who had issued

The Ookal Farmers Service Cooperative Society Limited, Warangal vs. ITO., Ward-1, Warangal

In the result, all three appeals of the assesssee, i

ITA 1144/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Dec 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 80PSection 80P(2)(d)

submitted that the Hon’ble Apex Court in its aforesaid judgment had held that, as per the mandate of Section 124(3) of the Act, an assessee is precluded from questioning the jurisdiction of the AO if he does not do Society Limited VS. ITO so within 30 days ... receipt of notice. The Ld. Sr. DR submitted that in the present case, the assessee as required per the mandate of Section 124(3) of the Act, had within the prescribed period not called in question the jurisdiction of the ITO, Ward 1, Warangal, i.e., the JAO, who had issued

Section 124(3)(a) — 106 case laws | BharatTax