ITA No 3329/Chny/2025 (AY 2015-16) Jay Chandra Rajan (Vs.) ITO ward 1 Tirunelvel

Parties Involved

Facts Summary

The captioned appeal by the assessee, JAYA CHANDRA RAJAN, arises out of the order of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi dated 05.11.2024 for Assessment Year 2015-16. The appeal was filed with a delay of 292 days, which was condoned based on a reasonable cause (Medical Certificate attached). The jurisdictional assessing officer (JAO) issued a notice u/s 148 dated 07.04.2022. The assessee argued that the notice should have been issued by the Faceless Assessing Officer (FAO) under the e-assessment of income assessment scheme, 2022, formulated by the CBDT Notification dated 29.03.2022. The respondent relied on the impugned order and argued that the CBDT Notification was not applicable. Various High Court judgments were cited by both parties on the issue of whether the JAO or FAO has the jurisdiction to issue notices under Section 148 of the Income-Tax Act, 1961.…

Legal Issues

• 1. Whether the notice u/s 148 dated 07.04.2022 was issued in accordance with the e-assessment of income assessment scheme, 2022.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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