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)

U/s 148 of the Act, dated 29/11/2023 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 151A and the "E- Assessment Scheme of Income Escaping Assessment Scheme, 2022" notified by the Government of India on 29.03.2022 under Section 151A

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:

U/s 148 of the Act, dated 11/04/2023 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 151A and the "E- Assessment Scheme of Income Escaping Assessment Scheme, 2022" notified by the Government of India on 29.03.2022 under Section 151A

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:

U/s 148 of the Act, dated 11/04/2023 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 151A and the "E- Assessment Scheme of Income Escaping Assessment Scheme, 2022" notified by the Government of India on 29.03.2022 under Section 151A

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

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

147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2022-23/1051563421(1) dated 29/03/2023 and annexed herewith for reference, 2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other allowance or deduction for the Assessment Year

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

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)

151A, and, thus, was bad and illegal; and (ii) that as the notice under section 148 of the Act, dated 27/04/2022 for the subject year, i.e., AY 2018-19 was issued by the AO beyond the period of three years from the end of the relevant assessment year, i.e., on 27/04/2022, therefore, as per the mandate of section

BILWA INFRASTRUCTURE LIMITED,HYDERABAD vs. ITO., WARD-1(1), HYDERABAD

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)

147 r.w.s 144B of the Act, dated 26/03/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order passed u/s 148A(d), dated 21/03/2023 and Notice u/s 148 of the Act, dated 21/03/2023, issued by the Income Tax Officer, Ward-1(1), Hyderabad, i.e., the JAO, as on date is squarely covered

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:

reassessment or recomputation under Section 147 of the Act and inapplicable to the issuance of notice under Section 148 of the Act. The Scheme is clearly applicable for issuance of notice under Section 148 of the Act and accordingly, it is only the FAO which can issue the notice under Section

KINETA GLOBAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

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

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, 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, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

151A of the Act. The Jurisdictional Assessing Officer (JAO) has no authority to pass order u/s 148A(d) and issue notice u/s 148 of the Act in contravention of judicial decisions. Hence the whole reopening proceedings and the assessment order are to be held as invalid. (Additional Ground) 4. The order of the Ld. CIT(A) dismissing the appeal

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:

147 r.w.s 144r.w.s 144B of the Act, dated 12/03/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order passed u/s 148A(d), dated 25/03/2023 and Notice u/s 148 of the Act, dated 25/03/2023, issued by the Income Tax Officer, Ward- 9(1), Hyderabad, i.e., the JAO, as on date is squarely covered

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)

147 r.w.s 144B of the Act, dated 31/01/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order passed u/s 148A(d), dated 24/04/2022 and Notice u/s 148 of the Act, dated 25/04/2022, issued by the ITO, Ward 1, Warangal, i.e., the JAO, as on date is squarely covered by the Judgment

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)

147 r.w.s 144B of the Act, dated 31/01/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order passed u/s 148A(d), dated 24/04/2022 and Notice u/s 148 of the Act, dated 25/04/2022, issued by the ITO, Ward 1, Warangal, i.e., the JAO, as on date is squarely covered by the Judgment

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)

147 r.w.s 144B of the Act, dated 31/01/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order passed u/s 148A(d), dated 24/04/2022 and Notice u/s 148 of the Act, dated 25/04/2022, issued by the ITO, Ward 1, Warangal, i.e., the JAO, as on date is squarely covered by the Judgment

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)

147 r.w.s 144B of the Act, dated 31/01/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order passed u/s 148A(d), dated 24/04/2022 and Notice u/s 148 of the Act, dated 25/04/2022, issued by the ITO, Ward 1, Warangal, i.e., the JAO, as on date is squarely covered by the Judgment

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

147 has been ensured. The Hon'ble Supreme Court in Union of India v. Ashish Agarwal [(2022) 444 ITR 1 (SC)] held that where reassessment notices were issued under the old regime but during the transition to the new faceless regime, such notices shall be treated as issued under Section 148A, thereby saving reassessment proceedings from being declared void. Though

MOHD SHOAIB UR RAHMAN,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(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)

reassessment under Section 147, 148 and 148A of the Act in a faceless manner.” 3. As the assessee by raising the additional grounds of appeal has sought our indulgence for adjudicating certain legal issues, which require looking no further beyond the facts available on record, therefore, we have no hesitation in admitting the same. Our aforesaid view is fortified

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:

147 r.w.s 144r.w.s 144B of the Act, dated 20/03/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order passed u/s 148A(d), dated 04/04/2022 and Notice u/s 148 of the Act, dated 05/04/2022, issued by the Income Tax Officer, Ward- 1(3), Tirupati, i.e., the JAO, as on date is squarely covered

SIVA SANKARA REDDY TUNGA,HYDERABAD. vs. ITO., WARD - 14(1), HYDERABAD.

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

Bench: Us:

147 r.w.s 144B of the Act, dated 11/03/2024 by the Assessment Unit, Income-Tax Department, i.e., Faceless Assessing Officer (FAO), based on the order 8 Siva Sankara Reddy Tunga vs. ITO passed u/s 148A(d), dated 25/03/2023 and Notice u/s 148 of the Act, dated 25/03/2023, issued by the Income Tax Officer, Ward-14(1), Hyderabad