RAMADEVI MUCHU,PAMIDIMUKKALA vs. ASSESSING OFFICER, GUDIWADA

ITA 90/VIZ/2026Status: DisposedITAT Visakhapatnam18 September 2026AY 2015-1633 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Act was barred by limitation as it was issued beyond the six-year period prescribed by the first proviso to Section 149(1)(b). Consequently, the reassessment order was quashed.

What were the facts?

The assessee's appeal challenges reassessment proceedings initiated under Section 148 of the Income Tax Act for AY 2015-2016. The primary contention is that the notice issued was barred by limitation as it was issued more than six years after the end of the assessment year.

What were the issues?

Whether the notice for reassessment under Section 148 was issued within the prescribed limitation period. Whether the addition of unexplained income under Section 69A was justified.

Which sections of the Income-tax Act were involved?

Section 148,Section 149,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM SMC-BENCH, VISAKHAPATNAM

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G

Pronounced: 18.09.2026

PER VIJAY PAL RAO, VICE PRESIDENT:

This appeal by the Assessee is directed against the Order dated 28.11.2025 of the learned CIT(A)-National Faceless Appeal Centre [in short "NFAC"], Delhi, for the assessment year 2015-2016. 2. The assessee has raised the following grounds of appeal:

1) “The reassessment proceedings initiated u/s 148 are bad in law, void ab initio and without j

The order continues below.

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