HARISH SADHWANI, RAIPUR,RAIPUR vs. ITO, WARD-3(1), RAIPUR, RAIPUR

ITA 144/RPR/2026Status: DisposedITAT Raipur17 September 2026AY 2013-146 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. Consequently, the reassessment order and the impugned order were quashed.

What were the facts?

The assessee's case was reopened for AY 2013-14 based on information about cash deposits and credit receipts not commensurate with declared income. The Assessing Officer (AO) taxed these under section 69A. The assessee appealed against the validity of the notice issued for reopening.

What were the issues?

The primary issue was whether the notice issued under section 148 of the Income Tax Act for reopening the assessment was time-barred. The secondary issue concerned the validity of the notice issued under the new regime after the expiry of the surviving time limit.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 149,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY, JM & SHRI AVDHESH KUMAR MISHRA, AM

For Appellant: Shri B. Subramanyam, CA
Hearing: 01/09/2026

Per Avdhesh Kumar Mishra, AM: This appeal for Assessment Year (‘AY’) 2013-14 filed by the assessee is directed against the order dated 09.12.2025 of Commissioner of Income Tax (Appeals), [‘CIT(A)’], National Faceless Appeal Centre (NFAC), Delhi, passed under section 250 of the Income Tax Act, 1961 (‘Act’).

2.

The assessee has raised following grounds of appeal:

“1. On the facts and in circumstances of the case,

The order continues below.

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