INCOME TAX OFFICER, CIVIL LINE, RAIPUR vs. RAIPUR DEVCON PVT. LTD., ANANDAM WORLD CITY

ITA 793/RPR/2025Status: DisposedITAT Raipur17 September 2026AY 2015-167 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 143(2) was time-barred and invalid, rendering the assessment void ab initio. The absence of a valid transfer order under Section 127 further invalidated the assessment proceedings.

What were the facts?

The Assessing Officer (AO) issued a notice under Section 143(2) beyond the prescribed time limit and without a valid transfer order under Section 127. The assessee's return was filed on September 1, 2015, making the deadline for the notice September 30, 2016, but it was issued on July 12, 2017.

What were the issues?

The key issues were the validity of the notice issued under Section 143(2) beyond the statutory time limit and the absence of a valid transfer order under Section 127, which are prerequisites for a valid assessment.

Which sections of the Income-tax Act were involved?

Section 143(2),Section 127,Section 142(1),Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY & SHRI AVDHESH KUMAR MISHRA

For Appellant: Shri R.B. Doshi, CA
For Respondent: Shri Rituparna Namdeo, CIT-DR
Hearing: 24.06.2026Pronounced: 17.09.2026

Heard together (2 matters)

ITA No.793/RPR/2025
CO No.06/RPR/2026

Read from the judgment's own cause title. This page is filed under one of them.

PER PARTHA SARATHI CHAUDHURY, JM: The captioned appeal preferred by the Revenue and corresponding cross objection by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, dated 17.10.2025 for the assessment year 2015-16 as per the grounds of appeal on record.

2.

In this case the Ld. CIT(A) had provided relief to the assessee on the ground that the assessee filed its return of income on 01.09.2015. T

The order continues below.

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