ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1019/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Sh. Anup Kumar Aggarwal Acit (Central) बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Adjpk-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Additions Of Rs.10.95 Lacs U/S 69 & Another Addition Of Rs.16.21 Lacs U/S 69A. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

reassessment, recomputation or issuance or sanction of notice with dynamic jurisdiction, as set out in clauses (a), (b) and (c) of sub-section 151A of the Act. 15. Thus, on a bare reading of section 151A as it stands, read with the scheme notified thereunder, we are of the clear opinion that the observations as contained in Paragraphs

ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

reassessment, recomputation or issuance or sanction of notice with dynamic jurisdiction, as set out in clauses (a), (b) and (c) of sub-section 151A of the Act. 15. Thus, on a bare reading of section 151A as it stands, read with the scheme notified thereunder, we are of the clear opinion that the observations as contained in Paragraphs

DCIT, CC-3, LUDHIANA, KITCHLU NAGAR vs. MANI RAM BALWANT RAI HUF, CIVIL LINES

In the result, Cross Objection filed by the assessee is allowed and appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 The Dcit, Mani Ram Balwant Rai, Huf, Central Circle-3, Vs Civil Lines, Opposite Session Court(Old) Kitchlu Nagar, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent & C.O. 43/Chd/2024 In आयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 Mani Ram Balwant Rai, Huf, The Dcit, Civil Lines, Opposite Session Court(Old) V Central Circle-3, Ludhiana. S Kitchlu Nagar, Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent Revenue By : Smt. Kusum Bansal, Cit Dr Assessee By : Shri Pankaj Bhalla, Ca & Shri Hunny Bajaj, Advocate Date Of Hearing : 17.07.2025 Date Of Pronouncement : 01.09.2025 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

Section - 151A, Income-tax Act, 1961 – FA 2023 [Faceless assessment of income escaping assessment.] 151 A. (1) The Central Government may make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment

GURJIT SINGH,ROPAR vs. INCOME TAX OFFICER, RUPNAGAR

Appeal stand allowed accordingly

Bench: Tribunal.

reassessment, recomputation or issuance or sanction of notice with dynamic jurisdiction, as set out in clauses (a), (b) and (c) of sub-section 151A of the Act. 15. Thus, on a bare reading of section 151A as it stands, read with the scheme notified thereunder, we are of the clear opinion that the observations as contained in Paragraphs

KEWAL KRISHAN, CHANDIGARH,CHANDIGARH vs. JOA DCIT/ACIT/JCIT(OSD)(CENTRAL CIRCLE) 1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section 148 was issued by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC), which is in violation of the mandatory procedure prescribed under Section 144B and Section 151A

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section 148 was issued by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC), which is in violation of the mandatory procedure prescribed under Section 144B and Section 151A

KEWAL KRISHAN CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) (CENTRAL CIRCLE) 1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section 148 was issued by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC), which is in violation of the mandatory procedure prescribed under Section 144B and Section 151A

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH ,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section 148 was issued by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC), which is in violation of the mandatory procedure prescribed under Section 144B and Section 151A

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) CENTRAL CIRCLE-1, CHANDIGARH , CHANDIGARH

In the result, all the above appeals are partly allowed

reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section 148 was issued by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC), which is in violation of the mandatory procedure prescribed under Section 144B and Section 151A

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT (OSD) CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section 148 was issued by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC), which is in violation of the mandatory procedure prescribed under Section 144B and Section 151A

KEWAL KRISHAN, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT JCIT (OSD)(CENTRAL CIRCLE)-1, CHANDIGARH., CHANDIGARH

In the result, all the above appeals are partly allowed

reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961 are bad in law and void ab initio, as the notice under Section 148 was issued by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC), which is in violation of the mandatory procedure prescribed under Section 144B and Section 151A

INCOME TAX OFFICER, WARD-1, JIND, JIND vs. VIKAS JAIN, JIND

In the result, the assessee succeeds in its cross-objection

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.838/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Income Tax Officer Shri Vikas Jain बनाम/ Ward 1 Nav Bharat Steel & General Industries Vs. Jind-126102. Indira Bazar, Jind-126102. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aeqpj-3689-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Co No. 28/Chandi/2025 [In Ita No.838/Chandi/2024) Shri Vikas Jain Income Tax Officer बनाम/ Nav Bharat Steel & General Industries Ward 1 Vs. Indira Bazar, Jind-126102. Jind-126102. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aeqpj-3689-E (Cross Objector) : (Respondent) Assessee By : Shri Suresh Gupta (Ca) – Ld. Ar Revenue By : Smt. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 01-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 11/11/2025

151A of the IT Act notified by CBDT through notification dated 29.03.2022 and therefore, the reassessment proceeding need to be quashed. 3. The impugned reassessment is invalid and without jurisdiction as the said assessment is completed without completing complying with the legal requirements of the provisions of section 147 / 148A(b) / 148A(d) / 151 / 148 / 149(1

HARMIT KAUR,YAMUNANAGAR vs. ITO, WARD-3, YAMUNANAGAR

In the result, the appeal of the assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 144B, 151A readwith notification dated 29.03.2022 issued thereunder is quite lucid. There is no ambiguity in the language of statutory provisions, thus, office memorandum or any other instruction issued by Board or any other authority cannot be relied upon." 8.2 Following the above binding precedent, we hold that the notice issued u/s 148 by the Jurisdictional AO is invalid

KUSUM MITTAL,SANGRUR vs. INCOME TAX OFFICER, WARD - SANGRUR, SANGRUR

In the result, the appeal of the assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

151A introducing the Faceless Reassessment Scheme, making it mandatory that notices under section 148 shall be issued through automated allocation in a faceless manner. The Hon’ble Punjab & Haryana High Court in Jatinder Singh Bhangu and Jasjit Singh has categorically held that where the statute mandates issuance of notice by the Faceless Assessing Officer, any notice issued by the Jurisdictional

ABHIMANYU GUPTA ,PATIALA vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-PATIALA , PATIALA

In the result, the appeal of the assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

151A read with the CBDT Notification dated 29.03.2022. 8.2 The reassessment proceedings have thus been initiated by an authority not vested with jurisdiction under the Faceless Assessment Scheme. This issue stands conclusively settled by the judgments of the Hon’ble Punjab & Haryana High Court in Jatinder Singh Bhangu and Jasjit Singh and the Hon’ble Bombay High Court in Hexaware

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex