LALIT NAYAK, RAIPUR,RAIPUR vs. ITO-4(1), RAIPUR, RAIPUR

ITA 428/RPR/2026Status: DisposedITAT Raipur17 September 2026AY 2014-155 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 Assessing Officer reopened the assessee's case for AY 2014-15 due to unexplained investment in property and cash deposits. The assessee's original return declared a much lower income. The Assessing Officer taxed these amounts under sections 69 and 69A, and the CIT(A) dismissed the appeal.

What were the issues?

The primary issue was the validity of the notice issued under section 148 of the Act, specifically whether it was issued within the prescribed time limits.

Which sections of the Income-tax Act were involved?

Section 69,Section 69A,Section 148,Section 148A,Section 149(1)

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 R. B. Doshi, CA
Hearing: 02/07/2026

Per Avdhesh Kumar Mishra, AM: This appeal for Assessment Year (‘AY’) 2014-15 filed by the assessee is directed against the order dated 23.03.2026 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 three effective issues in this case: (i) Taxability of unexplained investment of Rs.50,69,000/- in propert

The order continues below.

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