MAMATHA GUBBALA,HYDERABAD vs. ITO., WARD-15(1), HYDERABAD

reassessment order.", "result": "Partly Allowed", "sections": ["Section 147", "Section 144", "Section 148A(b)", "Section 148", "Section 142(1)", "Section 251(1)(a)", "Section

INCOME TAX OFFICER, WARD-8(1), HYDERABAD vs. DAGUMATI SWATHI, HYDERABAD

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

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

section 151A Applying the above ratio, the notice issued to the present assessee on 13.05.2021 by the Jurisdictional AO, Ward-8(1), Hyderabad is held to be without jurisdiction. The subsequent continuation of reassessment through NFAC cannot cure the initial defect. Since the very foundation of reassessment is invalid, the reassessment order dated 26.04.2023 passed u/s 147 r.w.s. 144

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income-tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside.\" 17. Dealing with almost an identical situation pursuant to the decision of the Hon'ble Supreme Court in Union of India

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income-tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside." 17. Dealing with almost an identical situation pursuant to the decision of the Hon'ble Supreme Court in Union of India

SANJEEV KUMAR NALAM,HYDERABAD vs. ITO, WARD-1, NIRMAL

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.669/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Sanjeev Kumar Nalam Vs. Income Tax Officer Hyderabad Ward – 1 Pan:Avdpn0497L Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

reassessment order passed under section 147 read with section 144 of the Act dated 31.05.2023 is liable to be quashed

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(2), HYDERABAD vs. INDRANI PRASAD , NEW DELHI

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

144. Clause (b) of Section 158 BC by referring to Section 143(2) and (3) would appear to imply that. the provisions of Section 143(1) are excluded. But Section 143(2) itself becomes necessary only where it becomes necessary to check the return, so that where block return conforms to the undisclosed income inferred by the authorities, there

INDRANI PRASAD ,NEW DELHI vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, HYDERABAD

In the result, the appeal is treated as allowed”

Bench: Shri A.M. Alankamony & Shri S.S. Godara

144. Clause (b) of Section 158 BC by referring to Section 143(2) and (3) would appear to imply that. the provisions of Section 143(1) are excluded. But Section 143(2) itself becomes necessary only where it becomes necessary to check the return, so that where block return conforms to the undisclosed income inferred by the authorities, there

PRABHAKAR REDDY BASIREDDY, NALGONDA vs. DCIT., CENTRAL CIRCLE-1(1) , HYDERABAD

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

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

144 to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier; (c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of 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

144 to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier; (c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section

THILAK BABU BOPPANA,CHITTOR vs. INCOME TAX OFFICER, WARD-1(1), TIRUPATI

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

Bench: Shri Manjunatha G. (Accountant Member), Shri Ravish Sood (Judicial Member)

144 r.w.s 44B of the Act, dated 28/02/2025 based on the order passed under Section 148A(d) of the Act, dated 24/02/2024 and Notice issued U/s 148 of the Act, dated 24/02/2024 by the Income Tax Officer, Ward- 1(1), Tirupati i.e., the “Jurisdictional Assessing Officer” (JAO). 14. In our view, the issue involved in the present appeal

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)

144(b) r.w Section 151A of the Act, therefore, the challenge by the assessee to the inherent lack of jurisdiction with the JAO to issue the notice under Section 148 of the Act will not be saved by the judgment of the Hon’ble Supreme Court in Commissioner of Income-tax (Exemption) v. Kalinga Institute of Industrial Technology (supra), which

PALLAPU SRINIVASARAO (HUF),ALMASGUDA vs. ITO., WARD-9(1), HYDERABAD

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

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

section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (for short, 2 Pallapu Srinivasa Rao (HUF) vs. ITO “the Act”), dated 17/02/2025 for the Assessment Year (AY) 2020-21. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal: 1. “The order of learned Commissioner of Income Tax (Appeals

DILEEP KUMAR SAKAMURI CHENCHU VENKATA,SRIKALAHASTI vs. INCOME-TAX OFFICER, WARD-1(3), TIRUPATI

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

Bench: Us:

144 r.w.s 44B of the Act, dated 20/03/2024 based on the order passed under Section 148A(d) of the Act, dated 04/04/2022 and Notice issued U/s 148 of the Act, dated 05/04/2022 by the Income Tax Officer, Ward- 1(3), Tirupati i.e., the “Jurisdictional Assessing Officer” (JAO). 14. In our view, the issue involved in the present appeal

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:

144 to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier; (c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section

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:

144 to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier; (c) where an action has been taken under section 132 or section 132A, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section

DESU ENTERPRISES,ONGOLE vs. ITO., WARD-1, ONGOLE

In the result, the appeal of the assessee in ITA No

reassessment proceedings under Section 147, and the CIT(A) upheld these.", "held": "The Tribunal held that the notice under Section 148 of the Income Tax Act, 1961, was issued on 01.04.2021. As this date falls after the amendment to Section 148 by the Finance Act, 2021, the mandatory procedure prescribed under Section 148A was required to be followed. Since

SRI EDUPAYALA VANA DURGA BHAVANI,HYDERABAD vs. INCOME TAX OFFICER, WARD-1, SANGAREDDY

Bench: Us:

144 r.w.s. 147 of the Income Tax Act, 1961 (for short, “the Act”) dated 29.03.2022 for A.Y. 2016-17. 2. The assessee has assailed the impugned order on the following grounds of appeal before us: “1. The order of Learned Principal Commissioner of Income Tax (PCIT) is erroneous both in fact in law. Furthermore, the invocation of Section

LAXMI VENKATA KRISHNA RICE CORPORATION,NALGONDA vs. ITO, WARD-1, SURYAPET

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

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

Section 147 r.w.s 144 r.w.s 144B of the Act, dated 16/03/2023 cannot be sustained and is liable to be quashed on the said count itself. 12. Per contra, Shri S. Arun Kumar, Learned Senior Departmental Representative (for short “Ld. Sr-DR”), on being confronted with the aforesaid factual position as was canvassed before us, failed to rebut the same. However