JAY RASHMI DIAMOND PVT. LTD.,SURAT vs. THE INCOME-TAX OFFICER, WARD 1(1)(3), SURAT., SURAT

ITA 58/SRT/2025Status: DisposedITAT Surat18 September 2026AY 2014-157 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were barred by limitation and without jurisdiction, following Supreme Court and Gujarat High Court decisions regarding the validity of notices issued after specific dates.

What were the facts?

The assessee's case was reopened for AY 2014-15. Notices under Section 148 were issued after the prescribed time limits, and the assessee challenged the validity of these notices.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated by issuing notices under Section 148 beyond the statutory time limits prescribed by law.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 68,Section 145

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Respondent: Shri Aashish Pophare, CIT(DR)
Pronounced: 18.09.2026

PER : SUCHITRA KAMBLE, J M:

The appeal filed by the assessee is against the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [in short “CIT(A)”] dated 25.11.2024 for the Assessment Year (in short “AY”) 2014-15. 2. The assessee has raised the following grounds of appeal: “1 The Ld. AO has erred in reopening the case u/s 147 of the Act by issuing the notice u/s 148 of the Ac

The order continues below.

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