NARENDRASINH CHANDANSINH SOLANKI,AHMEDABAD vs. THE ITO, WARD-3(3)(2), AHMEDABAD

ITA 1478/AHD/2025Status: DisposedITAT Ahmedabad23 September 2026AY 2017-184 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Income Tax Act was barred by limitation, as both the order under Section 148A(d) and the notice under Section 148 were passed after the expiry of the balance survival period.

What were the facts?

The assessee's appeal was against an order dismissing their appeal against a reassessment order. The primary contention was that the notice under Section 148 was issued beyond the limitation period and without following prescribed procedures.

What were the issues?

Whether the reassessment proceedings initiated by issuing a notice under Section 148 were barred by limitation due to non-compliance with the prescribed time limits and procedures.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 148,Section 148A,Section 149

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, D” BENCH, AHMEDABAD

Per Rahul Chaudhary, Judicial Member:

1.

The present appeal has been preferred by the Assessee against the Order, dated 27/05/2025, passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 25/05/2023, passed under Section 147 read with Section 144 of the Income Act, 1961 [hereinafter referred to as ‘the Act’] for the Assessment Year 2017-2018. 2. When the appeal was taken up for hearing the Learned Authorised Representative for the Assessee pressed into service Ground No. 1

The order continues below.

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