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MD Mahimud SK Vs. ITO, Ward 3(1)

Case No: ITA Nos. 2230 & 2229/KOL/2024
Court: INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA
Date: 3/4/2025

Parties Involved

appellantMD Mahimud SK
respondentITO, Ward 3(1)

Facts Summary

The assessee, MD Mahimud SK, received a notice under section 148 of the Income Tax Act on 31.03.2021, requiring him to file the return of income within 30 days. The assessee complied and filed the return on 28.04.2021, declaring a total income of ₹ 2,25,800/-. The Assessing Officer (AO) initiated proceedings under section 147 of the Act and made an addition of ₹21,06,182/- to the assessee's income on account of unexplained credits. The assessment was framed under section 147 read with section 144B of the Act on 23.03.2022. The assessee challenged this assessment, arguing that the National Faceless Assessment Centre (NFAC) did not have the jurisdiction to conduct the assessment as the relevant provisions were not operational at the time.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the National Faceless Assessment Centre had the jurisdiction to conduct the assessment under section 151A read with section 144B of the Act prior to 29.03.2022.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

6 precedents cited in this judgement.

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MD Mahimud SK Vs. ITO, Ward 3(1) | ITA Nos. 2230 & 2229/KOL/2024 | 2025 | Opakhya