ZAMIRUDDIN PATIL,CANADA vs. INCOME TAX OFFICER - WARD 1, GADAG

ITA 1414/BANG/2026Status: DisposedITAT Bangalore09 September 2026AY 2018-198 pages
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What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal, citing sufficient cause. It held that the notice under section 148A(b) was invalid as it did not grant the mandatory minimum period of 7 days for response, following jurisdictional High Court decisions. Consequently, the reassessment proceedings and the assessment order were quashed.

What were the facts?

The assessee's appeals were delayed by approximately 150 days due to the assessee being a senior citizen residing abroad and not receiving hearing notices at the correct email address. The primary issue was that the notice under section 148A(b) of the Income Tax Act granted only 5 days for response, instead of the mandatory minimum of 7 days.

What were the issues?

Whether the reassessment proceedings are void ab initio due to the notice under section 148A(b) granting less than the mandatory minimum of 7 days for response. Whether the defect is curable under Section 292B of the Act.

Which sections of the Income-tax Act were involved?

Section 148A(b),Section 147,Section 144,Section 144B,Section 270A,Section 292B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SANDEEP SINGH KARHAIL

PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER:

The assessee has filed the present appeals against the separate impugned orders of even date 28.08.2025, passed under section 250 of the Income Tax Act (“the Act”), by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [“learned CIT(A)”], which in turn arose from the quantum and penalty

The order continues below.

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