BAPA SITARAM COAL,MORBI vs. INCOME TAX OFFICER, WARD 1, MORBI, MORBI

ITA 680/RJT/2026Status: DisposedITAT Rajkot10 September 2026AY 2017-1811 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment notice under section 148 of the Income Tax Act was issued beyond the 'surviving time' as per the directions of the Hon'ble Supreme Court in the case of Rajeev Bansal. Therefore, the reassessment proceedings were quashed.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings against the assessee for AY 2017-18 based on information regarding cash payments for coal purchases. The assessee denied these transactions. The AO made an addition of Rs. 51,29,000/- as unexplained expenditure, which was upheld by the CIT(A).

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated under Section 148 of the Income Tax Act, specifically concerning the time limits and the application of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 148,Section 69C,Section 115BBE,Section 148A(b),Section 148A(d),Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Hardik Vora, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 13/07/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to Assessment Year 2017- 18, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Commissioner of Income-tax (Appeals), dated 25.02.2026, which in turn arises out of an assessment order passed by the Assessing Officer u/s 147 r.w.s. 144B of the Act, on 25.05.2023. 2. The grounds of appeal raised by the asses

The order continues below.

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