Section 148 notice issued by a JAO instead of FAO is without jurisdiction: ITAT Chandigarh

Pooja Aggarwal Vs ACIT Central (ITAT Chandigarh) The assessee appealed against the order of the Commissioner of Income Tax (Appeals)-3, Gurgaon, dated 31 July 2025, for Assessment Year 2021-22. The assessment had been framed under Section 147 on 12 March 2025, following a departmental search conducted on 4 November 2022. The case was centralized under Section 127 on 28 July 2023. Subsequently, a notice under Section 148 was issued on 29 December 2023 by G Poojitha, DCIT/ACIT (Central), Shimla, who was the Jurisdictional Assessing Officer (JAO). The assessee had filed a return declaring income ...