NUTAN PANDEY,NEAR SUJATA CHAWK vs. ACIT/DCIT, CENTRAL CIR

ITA 269/RAN/2026Status: DisposedITAT Ranchi10 September 2026AY 2018-196 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148A(b) was invalid as it did not provide the mandatory seven clear days for response. Consequently, the entire reassessment proceedings and the subsequent revisionary order under Section 263 were quashed.

What were the facts?

The assessee's case was selected for scrutiny based on information about bogus sales and purchases. The Assessing Officer initiated reassessment proceedings under Section 147, making additions for bogus purchases and sales. The PCIT set aside the assessment order, finding it erroneous and prejudicial to revenue, directing a fresh assessment.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated due to a short notice period under Section 148A(b). The Tribunal also considered the sustainability of the Section 263 revision order based on this invalid reassessment.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 148A(b),Section 263,Section 69C,Section 144

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI RATNESH NANDAN SAHAY & SMT. RAJANI GUDURI

For Appellant: Shri Sharwan Kumar Jha, Advocate
For Respondent: Shri Manjit Singh, CIT-DR
Hearing: 06/08/2026Pronounced: 10/09/2026

PER: BENCH

1.

This appeal by the assessee is directed against the order of the ld. PCIT (Central), Patna at Ranchi [in short, the ld. PCIT] dated 31/03/2026 for the Assessment Year (AY) 2018-19, wherein the assessee has raised following grounds of appeal:

"

1.

Whether, a scrutiny assessment under Section 143(3) is passed, followed by reassessment proceedings under Section 147 (read with Section 148), and the Assessing Officer (AO) specifically examines issues but makes no additions in the final reassessment order, the revision under Section 263 is not sustainable in the eyes of law and fit to be quashed?

The order continues below.

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