RAVI SREE CHINTAPALLI,BHIMAVARAM vs. INCOME TAX OFFICER, BHIMAVARAM

ITA 266/VIZ/2026Status: DisposedITAT Visakhapatnam19 August 2026AY 2015-1646 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that if the actual cash deposit in the bank account is less than Rs. 50 lakhs and this fact was brought to the notice of the Assessing Officer, then a notice issued under Section 148 after the expiry of three years from the end of the assessment year is invalid and liable to be quashed. Consequently, the reassessment order is also vitiated.

What were the facts?

The assessee's assessment was reopened beyond the prescribed time limit. The Assessing Officer issued a notice under Section 148 of the Income Tax Act, 1961, after the expiry of three years from the end of the assessment year, based on alleged escaped income. The assessee argued that the actual cash deposits were less than Rs. 50 lakhs, making the reopening notice time-barred.

What were the issues?

Whether the notice for reopening of assessment under Section 148 was issued within the prescribed limitation period, considering the actual amount of cash deposits.

Which sections of the Income-tax Act were involved?

Section 148,Section 149(1)(b)

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: 11.08.2026Pronounced: 19.08.2026

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 21.01.2026 of the learned CIT(A)-National Faceless Appeal Centre [in short "NFAC"], Delhi, for the assessment year 2015-2016. 2. The assessee has raised the following grounds of appeal:

2 ITA.No.266/Viz./2026 1. “Ground No. 1 General Ground Improper appreciation of facts. The learned Commissioner of Income Tax Appeals erred in confirming the addition made by the Assessing Officer towards cash deposits without properly appreciating the factual matrix of the case, including the nature and source of deposits and the corresp

The order continues below.

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