PIPODRA TEXTILE PARK PRIVATE LIMITED,SURAT vs. ITO, WARD-2(1)(3), SURAT

ITA 1364/SRT/2025Status: DisposedITAT Surat17 September 2026AY 2013-1411 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was time-barred as it was issued beyond the 'surviving time' allowed by Supreme Court directions. Consequently, the reassessment order was quashed.

What were the facts?

The assessee's income tax return for AY 2013-14 was assessed. Subsequently, the AO reopened the case under Section 147 based on information received. A fresh notice under Section 148 was issued on 29.06.2022, leading to an reassessment order.

What were the issues?

Whether the notice issued for reassessment under Section 148 was valid considering the time limits prescribed by Supreme Court judgments regarding the 'surviving time' for issuing such notices.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

For Appellant: Shri Ramesh Malpani, AR
For Respondent: Shri Ashish Kumar, Sr. DR
Hearing: 19.08.2026Pronounced: 17.09.2026

Per B.M. Biyani, AM:

Feeling aggrieved by order of first appeal dated 23.10.2025 passed by learned Commissioner of Income-Tax (Appeals)-National Faceless Appeal Centre, Delhi [“CIT(A)”], which in turn arises out of assessment-order dated 16.05.2023 passed by learned Assessment Unit of Income-tax Department [“AO”] u/s 147 r.w.s. 144 & 144B of Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2013-14, the assessee has filed this appeal.

2.

The background facts leading to present appeal are as under: Pipodra Textile Park Private Limited

(i) The assessee-company filed its return of income of AY 20

The order continues below.

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