Quote for the Day:

"Past of ice is water, future of ice is water too, 
so live like ice, no regrets for past, no worries about future"

Important Case Law:

“Reassessment quashed as 148 notice issued by JAO outside mandatory faceless scheme under section 144B: ITAT"

Where order under section 148A(d) and notice under section 148 were issued by Jurisdictional Assessing Officer after introduction of faceless reassessment scheme under section 144B read with section 151A and E-Assessment of Income Escaping Assessment Scheme, 2022, reassessment completed under section 147 read with section 144B treating cash deposits as unexplained money under section 69A was without jurisdiction and liable to be quashed.

Case Analysis:  Mohd. Shoaib UR Rahman Vs. Income-tax Officer

Date:                 January 16, 2026

Citation:            [2026] 183 taxmann.com 765 (Hyderabad - Trib.)

Facts of the Case:

• The Assessing Officer based on specific information flagged as per Risk Management Strategy, formulated by the CBDT through ITBA software under the head 'NMS cases', which revealed that the assessee during the subject year had carried out substantial financial transactions, viz., (i) purchase/sale of equity shares; and (ii) cash deposits in bank account, but had not filed his return of income for the year under consideration, initiated proceedings under section 148A..

• The ITO, Ward-4(1), Hyderabad, i.e., Jurisdictional Assessing Officer (JAO) passed an order under section 148A(d). Thereafter, the JAO issued notice under section 148. In response, the assessee filed his return of income for assessment year 2015-16, declaring an income of Rs. 1.69 lakhs.

• Thereafter, the Faceless Assessing Officer (FAO)vide his order under section 147 read with section 144B after making an addition of the unexplained cash deposits made by the assessee in his bank account under section 69A of Rs. 1.33 crores, determined his income at Rs. 1.35 crores.

• On appeal, the Commissioner (Appeals) also upheld the order of the FAO.

• On appeal to the Tribunal.

For Judgment,  Please click here

Useful Updates:

( Contribution by CA. R S Kalra,  Co-Founder - Voice of CA )

• A very insightful and informative article on “TDS on Professional or Technical Fees"  Read More

( Contribution by CA. Satish Agarwal )

• 										161 Legal Compliances and Legal Updates for Mar-2026 in India  Read More
  										

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