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2025 Supreme(Online)(ITAT) 7526

INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
SHRI VIJAY PAL RAO, VP, SHRI MADHUSUDAN SAWDIA, AM
Praveen Kumar – Appellant
Versus
The Income Tax Officer – Respondent


Advocates:
For the Assessee: CA PV Raghavendra Kumar, CA K A Sai Prasad
For the Revenue: Sri R. Kumaran, Sr. AR

आदेश/ORDER

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the order dated 30.06.2025 of learned CIT(A)-National Faceless Appeal Centre [in short “NFAC], Delhi, for the assessment year 2017-2018.

2. The assessee has raised the following grounds : 1. “The learned CIT(A) failed to consider the additional ground and submissions filed on 17.06.2025, wherein the appellant challenged the validity of reassessment u/s 147, since the notice u/s 148 was issued without the valid sanction mandated u/s 151, rendering the reassessment void ab initio.

2. The learned CIT(A) failed to appreciate that the notice u/s 148 issued by the Jurisdictional AO was in contravention of the Faceless Assessment/ Reassessment Scheme notified by CBDT, thereby rendering the reassessment void ab initio.

3. The learned CIT(A) failed to appreciate the fact that the notice u/s.148 did not contain a valid Document Identification Number (DIN) as mandated by CBDT Circular No.19/2019 dated 14.08.2019, thereby rendering the entire reassessment proceedings invalid.

4. The learned CIT(A) is not justified in upholding the reassessment order passed u/s 144 r.w.s. 147 without appreciating the fact t

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