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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
VIJAY PAL RAO, Vice President, MANJUNATHA G., Accountant Member
INCOME TAX OFFICER WARD-1 NIZAMABAD – Appellant
Versus
BHARAT THAKKER KALPANA NIZAMABAD – Respondent
| Table of Content |
|---|
| 1. reassessment notice under s.148 by jao challenged for lacking faceless compliance. (Para 1 , 2 , 3 , 4 , 6) |
| 2. revenue seeks abeyance pending supreme court slp. (Para 5) |
| 3. high courts consistently hold faceless s.148 mandatory. (Para 7) |
| 4. notice quashed following precedent; appeal dismissed subject to sc outcome. (Para 8 , 9 , 10) |
आदेश/ORDER
PER VIJAY PAL RAO, VICE PRESIDENT :
This appeal by the Revenue is directed against the Order dated 29.07.2025 of the learned CIT(A)-National Faceless Appeal Centre [in short “NFAC], Delhi, for the assessment year 2017-2018.
2. The Revenue has raised the following grounds in the instant appeal:
1. “The NFAC ought to have upheld the order both on facts and in law.
2. On the facts and circumstance of the case and in law, the NFAC erred in treating the notice u/s 148 issued by the JAO as invalid and issued without jurisdiction as per the provisions of section 151A of the Act.
3. The NFAC erred not considering the decision given by Hon'ble Calcutta High Court in the case of M/s Triton Overseas Pvt Ltd Vs Union of India in WPO/1566/2023 and which were decided the same issue in favour of Revenue.
4. Further, the NFAC ignored the MA filed (vi
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