Sun Power Life Battery Centre Vs ITO W 2 Tuticorin

Parties Involved

Facts Summary

The appeal arises from the order of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi dated 14.10.2025 for Assessment Year 2018-19. The assessee challenges the jurisdiction of the Jurisdictional Assessing Officer (JAO) to issue a notice under Section 148 dated 12.04.2022. The assessee argues that the notice should have been issued by the Faceless Assessing Officer (FAO) as per the CBDT Notification dated 29.03.2022, which introduced the e-assessment of income assessment scheme, 2022. The respondent contends that the CBDT Notification is not applicable in this case.…

Legal Issues

• 1. Whether the JAO has the jurisdiction to issue a notice under Section 148 of the Income Tax Act.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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