AKRUTI SECURITIES PRIVATE LIMITED,GUWAHATI vs. ACIT CENTRAL CIRCLE-1, GUWAHATI

ITA 377/GTY/2026Status: DisposedITAT Guwahati14 September 2026AY 2019-20206 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was barred by limitation as it was issued beyond the three-year period from the end of the relevant assessment year. Consequently, the assessment order was quashed.

What were the facts?

The assessee received Rs. 10 lakhs from a shell entity, which was confirmed by the directors of the shell entity during post-search proceedings. The Assessing Officer (AO) made an addition under Section 68, which was confirmed by the CIT(A).

What were the issues?

Whether the notice issued under Section 148 was within the prescribed limitation period. Whether the addition made under Section 68 was valid when the notice was time-barred.

Which sections of the Income-tax Act were involved?

Section 68,Section 147,Section 148,Section 149

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, GAUHATI

Before: Shri Laxmi Prasad Sahu & Shri Yogesh Kumar US

Per Laxmi Prasad Sahu Accountant Member:

This is an appeal filed by the assessee against the order passed by the CIT(A) Central NER, Guwahati order dated 10.01.2026 ITBA/APL/S/250/2025- 26/1084921328(1) u/s 250 of the Act on the following grounds of appeal:-

1.

FOR THAT ON THE FACTS AND CIRCUMSTANCES OF THE CASE AS WELL AS ON THE POINTS OF LAW THE ORDER PASSED U/S 147 R.W.S 143 AND U/S 250 ARE BAD IN L

The order continues below.

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