Order
22/08/2025
1. One of the grounds raised in this matter is that notice under
Section 148 of the Income Tax Act, 1961 (for short “the Act”) for
initiating re-assessment proceedings was issued by the
Jurisdictional Assessing Officer (JAO) and not Faceless Assessing
Officer (FAO) and therefore, notice itself is bad in law. Counsel
submitted that consequently the assessment order passed is also
bad in law.
[2025:RJ-JD:37688-DB] (2 of 3) [CW-6712/2025]
2. Counsel for Revenue Shri Bhandari submitted that assessee
participated in assessment proceedings without raising this ground
and therefore today after assessment order is passed, he cannot
challenge issue of jurisdiction on the ground that notice was to be
issued by the FAO and not JAO. He says that Section 124 of the
Act bars raising of issue of jurisdiction after 30 days of issuance of
notice under Section 142(1).