SAJJA KIRAN KUMAR,GUNTUR vs. THE INCOME TAX OFFICER, WARD-1(1), GUNTUR

ITA 18/VIZ/2026Status: DisposedITAT Visakhapatnam09 September 2026AY 2018-1922 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the approval for issuing the notice under Section 148 was obtained from an incorrect authority, as more than three years had elapsed from the end of the assessment year. Therefore, the reassessment proceedings were invalid.

What were the facts?

The Assessing Officer initiated reassessment proceedings under Section 147 based on information about substantial cash deposits in the assessee's bank account. The AO made an addition of Rs. 26,28,610/- as unexplained money. The CIT(Appeals) upheld the AO's order.

What were the issues?

Whether the reassessment proceedings were validly initiated considering the approval obtained for issuing the notice under Section 148, and whether the addition under Section 69A was justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 148A,Section 148,Section 69A,Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Before: SHRI MANJUNATHA G, HON’BLE & SHRI RAVISH SOOD, 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 19/09/2025, which in turn arises from the assessment order passed by the Assessing Officer (for short, “AO”) under Section 147 r.w.s 144B of the Income- tax Act, 1961 (for short,

The order continues below.

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