BABJAN ALLA BAKISH,KOLLEGAL CHAMARAJANAGAR DISTRICT vs. ITO, WARD - 1(1), MYSORE, MYSORE

ITA 206/BANG/2026Status: DisposedITAT Bangalore28 August 2026AY 2015-20165 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was barred by limitation as it was issued after the expiry of the six-year period from the end of the assessment year. Consequently, all subsequent proceedings were deemed unsustainable.

What were the facts?

The assessee did not file an income tax return for AY 2015-16. The Assessing Officer (AO) reopened the case to verify cash deposits of Rs. 87,34,250/-. The assessee explained the cash deposits were from his silk waste business, dealing with farmers, and that he mistakenly believed income tax would not apply. The AO estimated profit at 15%, which the CIT(A) reduced to 10%.

What were the issues?

Whether the notice issued under Section 148 for AY 2015-16 was barred by limitation. Whether the subsequent proceedings based on a time-barred notice are sustainable.

Which sections of the Income-tax Act were involved?

Section 139(1),Section 148,Section 142(1),Section 44AD,Section 149(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI BALAKRISHNAN S. & SHRI SOUNDARARAJAN K.

PER SHRI SOUNDARARAJAN K., JUDICIAL MEMBER:

This is an appeal filed by the assessee challenging the order of the NFAC, Delhi dated 29/09/2025 in respect of the A.Y. 2015-16. 2. The brief facts of the case are that the assessee is an individual and not filed his return of income u/s. 139(1) of the Act. Even though the 1 Babjan Alla Bakish

assessee had submitted that they have filed the return of income in response

The order continues below.

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