GANGASANI AMEETA REDDY,HYDERABAD vs. ITO, WARD-8(1), HYDERABAD

ITA 370/HYD/2026Status: DisposedITAT Hyderabad11 September 2026AY 2015-1616 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 for reopening the assessment was barred by limitation as per the first proviso to Section 149 of the Act. Consequently, the reassessment order passed by the AO was quashed.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under Section 147 for AY 2015-16 based on information about cash deposits in the assessee's bank accounts. The AO treated these deposits as unexplained income under Section 69A and made an addition. The CIT(Appeals) dismissed the assessee's appeal, partly due to delay and partly on merits.

What were the issues?

The primary issue was whether the notice for reopening the assessment was issued within the prescribed period of limitation under Section 149, considering the amendments brought by the Finance Act, 2021.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, HYDERABAD BENCHES, HYDERABAD

Before: SHRI RAVISH SOOD, HON’BLE & SHRI MADHUSUDAN SAWDIA, HON’BLE

PER RAVISH SOOD, JM: The present appeal filed by the assessee is directed against the order passed by the CIT(Appeals), NFAC, Delhi (for short, “CIT(A)”) dated 12/01/2026, which in turn arises from the assessment order passed by the Assessing Officer (for short, “AO”) under Section 147 r.w.s 144 r.w.s 144B of the Income-tax Act, 1961 (for short, “the Act”), dated 17/01/2024, for A.Y. 2015-

16.

The assessee has assailed the impugned order on the following grounds of appeal before us.

The order continues below.

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