Chandigarh ITAT Quashes Reopening as Notice u/s 148 Issued by JAO Instead of FAO

Sharmanji Yarns Pvt. Ltd. Vs ACIT (ITAT Chandigarh)

Chandigarh Tribunal delivered its order on 12-11-2025, arising out of reassessment framed u/s 147 r.w.s 144B. The core dispute related to the addition of alleged bogus purchases of Rs.29.69 Crores from four parties. CIT(A) had restricted the addition by estimating 9%. Both parties filed cross-appeals.

At the outset, the Ld. AR raised a pure legal ground contending that the very reopening is void since the notice u/s 148 dated 07-04-2022 was issued by the Jurisdictional Assessing Officer (JAO) instead of the Faceless Assessi

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