No.368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs ITO (ITAT Visakhapatnam)
Summary: The appeal was filed by No.368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited against the order dated 08.07.2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising from the assessment order passed under section 147 read with section 144B of the Income Tax Act, 1961 dated 15.03.2024.
The assessee challenged, among other matters, the validity of the notice under section 148 dated 30.03.2023 issued by the Jurisdictional Assessing Officer (JAO), contending that, after introduction of the “Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022” and the “E-Assessment Scheme of Income Escaping Assessment Scheme, 2022” under section 151A, the notice could only be issued through the prescribed faceless mechanism by the Faceless Assessing Officer (FAO).
The reassessment proceedings had originated from information disseminated under the Risk Management Strategy (RMS), according to which the assessee society had made cash deposits/withdrawals aggregating to Rs. 12,01,74,652/- in its bank account with The Guntur District Co-operative Central Bank Limited but had not filed its return of income. A notice under section 148 dated 30.03.2023 was consequently issued by the ITO, Ward-1, Tenali. The assessee subsequently filed its return for Assessment Year 2019-20 on 31.03.2023 declaring total income at NIL after claiming deduction under section 80P of Rs. 16,30,461/-.
