VALLABHANENI DURGA PRASAD,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-2(5), VISAKHAPATNAM

ITA 749/VIZ/2025Status: DisposedITAT Visakhapatnam19 August 2026AY 2015-1631 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Act on April 2, 2022, was barred by limitation as it was issued beyond six years from the end of the assessment year 2015-2016. Consequently, the reassessment order was quashed.

What were the facts?

The assessee's appeal challenges a reassessment order. The primary issue is the validity of the notice issued under Section 148 of the Income Tax Act, 1961, which was dated April 2, 2022.

What were the issues?

Whether the notice issued under Section 148 of the Income Tax Act, 1961, for reassessment was barred by limitation given the assessment year and the relevant provisions of Section 149.

Which sections of the Income-tax Act were involved?

Section 148,Section 149

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM DB BENCH VISAKHAPATNAM

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.

Hearing: 13.08.2026Pronounced: 19.08.2026

PER MANJUNATHA G. A.M. : This appeal by the assessee is directed against the Order dated 04.09.2025 of the learned CIT(A)-National

2 ITA.No.749/Viz./2025 Faceless Appeal Centre [in short “NFAC”], Delhi, for the assessment year 2015-2016. 2. The assessee has raised the following grounds of appeal:

1.

“The order of Learned Commissioner of Income Tax (Appeals) is contrary to the facts and also the law applicable to the facts of the case.

2.

The learned Commissioner of Income Tax (Appeals) ought to have quashed the notice dt.02.04.2022 issued u/s 1

The order continues below.

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