THE OOKAL FARMERS SERVICE COOPERATIVE SOCIETY LIMITED,WARANGAL vs. ITO., WARD-1, WARANGAL

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

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

Section 124 of the Act, then, having waived its said right, it was barred from raising the issue of jurisdiction after having participated in the assessment proceedings. The Hon'ble High Court had observed that the waiver can only be of one's right or privilege, but non-exercise of the same will not bestow jurisdiction on a person

THE OOKAL FARMERS SERVICE COOPERATIVE SOCIETY LIMITED,WARANGAL vs. ITO., WARD-1, WARANGAL

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

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

Section 124 of the Act, then, having waived its said right, it was barred from raising the issue of jurisdiction after having participated in the assessment proceedings. The Hon'ble High Court had observed that the waiver can only be of one's right or privilege, but non-exercise of the same will not bestow jurisdiction on a person

THE OOKAL FARMERS SERVICE COOPERATIVE SOCIETY LIMITED,WARANGAL vs. ITO., WARD-1, WARANGAL

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

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

Section 124 of the Act, then, having waived its said right, it was barred from raising the issue of jurisdiction after having participated in the assessment proceedings. The Hon'ble High Court had observed that the waiver can only be of one's right or privilege, but non-exercise of the same will not bestow jurisdiction on a person

MADURAI TUTICORIN EXPRESSWAYS LIMITED,HYDERABAD vs. ACIT., CIRCLE - 5(1), HYDERABAD

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

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

Section 124 of the Act, then, having waived its said right, it was barred from raising the issue of jurisdiction after having participated in the assessment proceedings. The Hon'ble High Court had observed that the waiver can only be of one's right or privilege, but non-exercise of the same will not bestow jurisdiction on a person

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

Bench: Us:

Section 124 of the Act, then, having waived its said right, it was barred from raising the issue of jurisdiction after having participated in the assessment proceedings. The Hon'ble High Court had observed that the waiver can only be of one's right or privilege, but non-exercise 13 Krishnaveni Kokkula vs. ITO of the same will not bestow

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 ...

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

reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 15.04.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name and designation of the JAO. It was submitted that the CBDT Notification No. 18/2022

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 ...

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

reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 15.04.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name and designation of the JAO. It was submitted that the CBDT Notification No. 18/2022

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 ...

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

reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 15.04.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name and designation of the JAO. It was submitted that the CBDT Notification No. 18/2022

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 ...

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

reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 15.04.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name and designation of the JAO. It was submitted that the CBDT Notification No. 18/2022

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

Bench: Us:

Section 124 of the Act, then, having waived its said right, it was barred from raising the issue of jurisdiction after having participated in the assessment proceedings. The Hon'ble High Court had observed that the waiver can only be of one's right or privilege, but non-exercise of the same will not bestow jurisdiction on a person

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

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.:

reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated Page 3 of 26 ITA No 1328 of 2025 Vijay Kumar Patil 27.03.2024 and the notice issued under section 148 of the Act on 28.03.2024. He demonstrated that both documents clearly bear the name and designation

CYIENT LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

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

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.913/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Shri Ankit Jain Vs. Acit Hyderabad Central Circle 1(2) Pan:Agwpa4459K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri V. Ravish Bhatt, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 07/11/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 30.03.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name and designation of the JAO. It was submitted that the CBDT Notification No. 18/2022

ANKIT JAIN, HYDERABAD. vs. DCIT., CENTRAL CIRCLE -1(2), HYDERABAD.

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

Bench: Us:

reassessment notice under Section 148, in case assigned to “Central Circle”, cannot be issued by JAO and has to be issued in a faceless manner as per the amended provisions brought in by Ankit Jain vs. ACIT/DCIT Finance Act, 2021 w.e.f 01.04.2021. The Ld. AR had placed on record the ITAT order in the case of Prabhakar Reddy Basireddy

ANKIT JAIN,HYDERABAD. vs. ACIT., CENTRAL CIRCLE - 1(2), HYDERABAD

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

Bench: Us:

reassessment notice under Section 148, in case assigned to “Central Circle”, cannot be issued by JAO and has to be issued in a faceless manner as per the amended provisions brought in by Ankit Jain vs. ACIT/DCIT Finance Act, 2021 w.e.f 01.04.2021. The Ld. AR had placed on record the ITAT order in the case of Prabhakar Reddy Basireddy

RASHID HUSSAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(3), HYDERABAD

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

124 is confined to a case where he objects to the assumption of jurisdiction by the A.O, and not otherwise. 17. Before proceeding further, it would be relevant to point out that a plain reading of sub-section (3) of Section 120 of the Act reveals that the "Jurisdiction" vested with the Income-tax Authorities is classified into four categories

ANKITJAIN,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD.

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

reassessment introduced by the CBDT. The Ld. AR invited\nour attention to the order under section 148A(d) of the Act, dated\n30.03.2022 and the notice issued under section 148 of the Act on\nthe same date. He demonstrated that both documents clearly bear\nthe name and designation of the JAO. It was submitted that the\nCBDT Notification No. 18/2022

ACIT, CIRCLE-2(1), HYDERABAD vs. Y S JAGAN MOHAN REDDY, KADAPA

In the result, cross objection filed by the assessee is\nallowed

124 & 127\nof the Act, and other provisions of the Act, submitted that the\nterm A.O would include JCIT after the amendment of Sec. 2 Sub\nSec. 7A by the Finance Act 2007 with retrospective effect from\n01.06.1994 which is evident from the notification issued by the\nCBDT u/s 120(1) & (2) of the Act, and also the order passed

SHIVA RANJANI VEJJA ,HYDERABAD vs. INCOME TAX OFFICER, WARD-12(2) , HYDERABAD

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

Bench: Shri R.K. Panda & Shri Laliet Kumar

section 124(3)(b) assessee could not call-in question jurisdiction of an AO after expiry of one month from date of a service of reassessment