When no addition on reopening issue, entire 147 proceeding falls JAO had no jurisdiction post-Faceless Scheme

Pitti Holdings Pvt. Ltd. Vs ACIT (ITAT Hyderabad)

When no addition on reopening issue, entire 147 proceeding falls & JAO had no jurisdiction post-Faceless Scheme

Notice by Jurisdictional AO instead of Faceless AO held invalid & reassessment without addition on original issue declared void

Assessee, M/s Pitti Holdings Pvt Ltd, challenged the order of CIT(A)-NFAC dated 16-01-2025 confirming reassessment framed u/s 147 r.w.s 144B.

Two legal defects were urged—

(1) that notice u/s 148 was issued by the Jurisdictional Assessing Officer (JAO) instead

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