Sambasivam Nandhavs. ITO, Non-Corporate Ward-3(2), Race Course, Coimbatore, Tamil Nadu

Parties Involved

Facts Summary

The assessee, Sambasivam Nandha, raised a jurisdictional ground against the order of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi dated 29.09.2025 for Assessment Year 2018-19. The jurisdictional assessing officer (JAO) issued a notice under section 148 dated 25.04.2022. The assessee contended that the notice should have been issued by the Faceless Assessing Officer (FAO) as per the CBDT Notification dated 29.03.2022, which formulated the 'e-assessment of income assessment scheme, 2022'. The respondent argued that the CBDT Notification was not applicable in this case. The Tribunal examined the submissions and relevant case laws.…

Legal Issues

• 1. Whether the notice under section 148 should have been issued by the JAO or the FAO as per the CBDT Notification dated 29.03.2022.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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