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

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

Bench: Us:

1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003 [but on or before the 31st

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:

1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003 [but on or before the 31st

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

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

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

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

151A(1) and (2) of the Act, which is to the following effect: Page 15 of 29 ITA Nos 1317 915 1487 and 1606 15. On perusal of para no. 3 of the said notification, it is evident that the assessment, re-assessment or re-computation under section 147 of the Act and any notice to be issued under section

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

151A(1) and (2) of the Act, which is to the following effect: Page 15 of 29 ITA Nos 1317 915 1487 and 1606 15. On perusal of para no. 3 of the said notification, it is evident that the assessment, re-assessment or re-computation under section 147 of the Act and any notice to be issued under section

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

151A(1) and (2) of the Act, which is to the following effect: Page 15 of 29 ITA Nos 1317 915 1487 and 1606 15. On perusal of para no. 3 of the said notification, it is evident that the assessment, re-assessment or re-computation under section 147 of the Act and any notice to be issued under section

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

151A(1) and (2) of the Act, which is to the following effect: Page 15 of 29 ITA Nos 1317 915 1487 and 1606 15. On perusal of para no. 3 of the said notification, it is evident that the assessment, re-assessment or re-computation under section 147 of the Act and any notice to be issued under section

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.:

151A(1) and (2) of the Act, which is to the following effect: 15. On perusal of para no. 3 of the said notification, it is evident that the assessment, re-assessment or re-computation under section 147 of the Act and any notice to be issued under section 148 of the Act on or after 29.03.2022 shall

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.:

151A(1) and (2) of the Act, which is to the following effect: 14. On perusal of para no. 3 of the said notification, it is evident that the assessment, re-assessment or re-computation under section 147 of the Act and any notice to be issued under section 148 of the Act on or after 29.03.2022 shall

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

DCIT (EXEMPTIONS), CIRCLE 1(1), HYDERABAD vs. NATIONAL INSTITUTE OF RURAL DEVELOPMENT AND PANCHAYATI RAJ, HYDERABAD

In the result, both the appeal filed by the Revenue and cross- objection filed by the assessee are dismissed

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

151A r.w. Section 144B of the Act and argued that, the notice issued by the Jurisdictional Assessing Officer (JAO) is bad in law and consequently the assessment order passed by the A.O. in pursuant to the invalid notice is liable to be quashed. The sum and substance of the arguments of the assessee before the Ld. CIT(A) are that

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