“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

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

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

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

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

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

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)

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

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

ITA 1143/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Dec 2025AY 2015-16

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

ACIT Circle-4(3)(1), Mumbai vs. Khadamat Integrated Solutions Pvt Ltd, Mumbai

ITA 3766/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Dec 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 250

just for the convenience of the Assessing Officer and / or the Revenue Authorities. Further, as per the provisions of section 124(3) of the Act, at this stage, the Assessee cannot be allowed to raise the objection with regard the jurisdiction of the Assessing Officer in passing the assessment order

Vikram Brahmendra Satyajit Mulpuri, Krishna Dist vs. Income Tax Officer, Ward-3(1), Vijayawada

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 534/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.534/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Vikram Brahmendra Satyajit Vs. Income Tax Officer, Mulpuri, Ward-3(1), Krishna District. Vijayawada. Pan: Aonpm1893G (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm:

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 144BSection 147Section 148Section 148ASection 250Section 69A

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 ITO, Ward 3(1), Vijaywada, i.e., the JAO, who had issued Notice under Section

Ankitjain, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed in

ITA 913/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, CA

Section 115BSection 147Section 148Section 148ASection 292CSection 69

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) 2000000 (3) No person shall be entitled to call in question the jurisdiction ... aside the notice issued u/s. 143(2) of the Act by the ACIT, Corporate Circle-1(2), Bhuwaneshwar. Elaborating on the scope of Section 124(3)(a) of the Act, the Hon'ble Apex Court observed Page 10 of 28 ITA No 913 of 2025 Ankit Jain Hyderabad that

Krishnaveni Kokkula, Hyderabad vs. ITO., Ward-9(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 558/HYD/2025[2016-17]Status: DisposedITAT Hyderabad17 Dec 2025AY 2016-17

Bench: Us:

Section 147Section 69A

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 ITO, Ward-9(1), Hyderabad i.e., the JAO, who had issued Notice under Section

Gattula Lakshmi Madhavi, Visakhapatnam vs. Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, the appeal filed by the assessee in ITA

ITA 387/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

that as the assessee had not called in question the assumption of jurisdiction by the JAO within the prescribed time period contemplated under section 124(3) of the Act, therefore, he is precluded from challenging the same for the first time in the course of the present proceedings before ... submitted that the Hon’ble Apex Court in clear and unequivocal terms in its aforesaid order had observed that Section 124(3)(a) precludes the assessee from questioning the jurisdiction of the AO, if he does not do so within 30 days of receipt of notice. Accordingly

Gattula Lakshmi Madhavi, Visakhapatnam vs. Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, the appeal filed by the assessee in ITA

ITA 386/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

Gattula Lakshmi Madhavi, Visakhapatnam vs. Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, the appeal filed by the assessee in ITA

ITA 385/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

Deputy Commissioner of Income Tax, Circle 3(1), Visakhapatnam vs. Doddi Roopa, Visakhapatnam

In the result, the appeal filed by the revenue is dismissed in terms of our aforesaid observations

ITA 413/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2019-20

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.413/Viz/2024 (िनधा"रण वष"/Assessment Year: 2019-20) Deputy Commissioner Of Vs. Smt. Doddi Roopa, Income Tax, Visakhapatnam. Circle-3(1), Visakhapatnam. Pan: Atfpr7237N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement:

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri Badicala Yadagiri

Section 131Section 133(6)Section 147Section 148Section 148A

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 10 DCIT vs. Smt. Doddi Roopa period not called in question the jurisdiction of the DCIT/ACIT, Circle- 3(1), Visakhapatnam

Satyanarayana Koduru, Krishna Dist vs. Income Tax Officer, Ward-1, Gudiwada

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 491/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.491/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Satyanarayana Koduru, Vs. Income Tax Officer, Krishna District. Ward-1, Pan:Altpk1048C Gudiwada. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 144BSection 147Section 148Section 148ASection 250Section 69Section 69A

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 ITO, Ward 1, Gudiwada, i.e., the JAO, who had issued Notice under Section

Venkata Ramana Goda, Visakhapatnam vs. Assisstant Commissioner of Income Tax, Circle-3(1), Visakhapatnam

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 489/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.489/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Venkata Ramana Goda, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Circle-3(1), Pan: Abzpg3216A Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 17/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 08/03/2025. The 2 Venkata Ramana Goda Vs. Acit

For Appellant: Mrs. K. Hemalatha, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 133(6)Section 147Section 148Section 151ASection 2(14)(iii)Section 234ASection 234BSection 250

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 DCIT/ACIT, Circle- 3(1), Visakhapatnam, i.e., the JAO, who had issued Notice under Section

Go Iron Marketing, Visakhapatnam vs. Income Tax Officer, Ward 3(3), Vishakapatnam

In the result, the appeal filed by the assessee firm is allowed in terms of our aforesaid observations

ITA 483/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.483/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Go Iron Marketing, Vs. Income Tax Officer, Visakhapatnam. Ward-3(3), Pan: Aanfg6474D Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca (Hybrid Hearing) राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of 03/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 26/07/2025 Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 01/02/2024 For The Assessment Year 2018-19. The 2 Go Iron Marketing Vs. Ito

For Appellant: Mrs. K. Hemalatha, CAFor Respondent: Shri Badicala Yadagiri, CIT-DR

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 151ASection 250

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 firm 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 ITO, Ward 3(3), Visakhapatnam, i.e., the JAO, who had issued Notice under Section

No 368 Kolakaluru Primary Agricultural Co Operative Credit Society Limited, Guntur vs. Income Tax Officer, Ward-1, Tenali

In the result, the appeal filed by the assessee society is allowed in terms of our aforesaid observations

ITA 456/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.456/Viz/2025 (िनधा"रण वष"/Assessment Year:2019-20) No.368 Kolakaluru Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-1, Credit Society Limited, Tenali. Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W Section 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 144Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 80PSection 80P(2)(a)Section 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 6 No.368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited vs. ITO the jurisdiction of the AO, if he does ... days of 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 time period not called in question the jurisdiction of the ITO, Ward 1, Tenali

Venkata Ramanamma Sakamuri, Marripadu, Nellore vs. ITO., Ward-1, Nellore

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 299/HYD/2025[2019-20]Status: DisposedITAT Hyderabad05 Dec 2025AY 2019-20

Bench: Us:

Section 144Section 148Section 148A

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 ITO, Ward-1, Nellore i.e., the JAO, who had issued Notice under Section

Paila Venkata Padmavathi, Visakhapatnam vs. Income Tax Officer, Ward-5(3), Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 121/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.121/Viz/2024 (निर्धारण वर्ा/ Assessment Year:2015-16) Vs. Paila Venkata Padmavathi The Income Tax Officer Ward– 5(3) 3-47, Thanam Aayakar Bhavan Paravada Mandal Dabagardens, Visakhapatnam Paravada – 531021 Andhra Pradesh Andhra Pradesh [Pan: Bsipp1954P]

Section 131Section 143(1)Section 143(2)Section 143(3)Section 156Section 282(1)

before lower authorities. Ld. DR further submitted that assessee has to raise its objection within a period of thirty days as provided under section 124(3)(a) of the Act. He therefore pleaded that the assessment order cannot be quashed which is curable as per section 292BB ... Assessee ought to have raised this issue before the Ld. AO, within 30 days from the receipt of notice as provided in section 124(3)(a) of the Act. Since the assessee failed to raise this issue before the Ld. AO within the period of one month and participated

Ajithkumar Singu, Guntur vs. Income Tax Officer, Ward (International Taxation), Vijayawada

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 348/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2021-22

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.348/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2021-22) Vs. Ajithkumar Singu The Income Tax Officer Ward (International Taxation) D.No. 8-76-1, Murikipudi Income Tax Office Chilakaluripeta C.R. Building, Annex Ramachandrapuram M.G. Road Guntur – 522626 Vijayawada – 520002 Andhra Pradesh Andhra Pradesh [Pan: Etxps2554D]

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 69A

before lower authorities. Ld. DR further submitted that assessee has to rise its objection within a period of thirty days as provided under section 124(3)(a) of the Act. He also submitted that it is curable as per section 292BB of the Act. He therefore pleaded that the assessment

Rakesh Chopra, Delhi vs. Income Tax Officer, Delhi

In the result, Appeal of the Assessee is allowed

ITA 4807/DEL/2024[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalrakesh Chopra, Vs. Income Tax Officer, J-369, New Rajinder Nagar Ward-50(3), Room No.1409, E- Delhi-110060 2, Block, Civic Centre, Delhi-110060 Pan No:-Addpc4553C Appellant Respondent Assessee By Ms. Manju Goel, Ca & Shri B.L. Gupta, Ca Revenue By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 26 .11.2025

Section 124(3)(a)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 69

erred by stating that the appellant cannot question the jurisdiction of AO as per the provisions of section 124(3)(a) of The Income tax Act,1961 relying on the Hon'ble Supreme court decision in the case of DCIT vs Kalinga Institute of Industrial Technology (2023) 151 taxmann.com

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 144CSection 153CSection 153DSection 250

objections to jurisdiction were not entertained being time barred because the Assessee in that case failed to timely challenge the jurisdiction as per Section 124(3)(a) of the Act. However, the said judgment is not applicable in the present case. 22. In the present case, the very initiation ... complete absence of jurisdiction in violation of CBDT guidelines or direction as issued u/s 120 of the Act. 23. Further, according to Section 124(3)(c) of the Act, the Assessee has the right to object to the jurisdiction at any time within one month from the date the notice

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 144CSection 153CSection 153DSection 250

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 144CSection 153CSection 153DSection 250