PATTABHI RAMAYYA AYYAGARI,HYDERABAD vs. INCOME TAX OFFICER, WARD 11(1), HYDERABAD, HYDERABAD

ITA 1680/HYD/2026Status: DisposedITAT Hyderabad18 September 2026AY 2015-1624 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was issued beyond the limitation period prescribed by Section 149(1)(b) for AY 2015-16. Consequently, the reassessment proceedings and the assessment order were quashed.

What were the facts?

The assessee did not file a return for AY 2015-16. The AO initiated reassessment proceedings and issued a notice under Section 148 on April 3, 2022. The assessee's appeal was dismissed by the CIT(A) who upheld an addition of Rs. 30,00,000.

What were the issues?

Whether the notice issued under Section 148 of the Income Tax Act was barred by limitation. Whether reassessment proceedings initiated on a time-barred notice are valid.

Which sections of the Income-tax Act were involved?

Section 148,Section 149(1)(b),Section 69A,Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘ SMC ‘ Bench, Hyderabad

Before: Shri Vijay Pal Rao, Vice-Shri Madhusudan Sawdia

Hearing: 24/08/2026

Per Madhusudan Sawdia, A.M.:

This appeal is filed by Shri Pattabhi Ramayya Ayyagari, (“the assessee), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 10.03.2026 for the A.Y.2015-16. 2. The assessee has raised the following grounds of appeal:

“1. On the facts and in the circumstances of the case, the order of the Id. CIT(A) is erroneous both on facts and in law.

2.

The Id. CIT(A) erred in sustaining the addition made by the AO o

The order continues below.

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