SATYANARAYANA MURTHY BOLLEMPALLI,NARASAPUR vs. INCOME TAX OFFICER, WARD -1, PALAKOLE

ITA 315/VIZ/2025Status: DisposedITAT Visakhapatnam09 September 2026AY 2015-169 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the show cause notice issued by the AO was invalid as it provided less than the mandatory minimum period of 7 days for the assessee to reply. Consequently, the reopening of assessment and the reassessment order were vitiated.

What were the facts?

The assessee's appeal challenges the validity of the reopening of assessment. The Assessing Officer (AO) issued a show cause notice under Section 148A(b) allowing only 6 days for the assessee to reply, which is less than the mandatory minimum of 7 days prescribed by law.

What were the issues?

Whether a show cause notice issued under Section 148A(b) allowing less than the mandatory minimum period of 7 days for reply is invalid, and if so, whether it vitiates the subsequent reopening of assessment.

Which sections of the Income-tax Act were involved?

Section 148A(b),Section 148A(d)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH

Before: SHRI VIJAY PAL RAO, HON’BLE & SHRI MANJUNATHA.G, HON’BLE

Hearing: 22.07.2026Pronounced: 09.09.2026

PER VIJAY PAL RAO, VP:

This appeal by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 11.04.2025, for assessment year 2015-16. 2. The assessee has raised the following grounds of appeal: Satyanarayana Murthy Bollempalli 1. The impugned order of the learned Authorities below in so far as it is against the appellant is opposed to law, weight of evidence, natural justice,

The order continues below.

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