MAHADEVI,MATHURA vs. ITO, WARD 4(3)(4), HATHRAS

ITA 358/AGR/2026Status: DisposedITAT Agra18 August 2026AY 2019-208 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment framed without issuing a notice under Section 143(2) in response to a belatedly filed return is bad in law and void ab initio. Therefore, the reassessment order was quashed.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings as the assessee did not file a return of income. The assessee later filed a return, which the AO treated as invalid. The AO made additions based on property purchase and stamp duty value, without issuing a notice under Section 143(2) for the belatedly filed return.

What were the issues?

Whether an assessment framed under Section 147/148 without issuing a notice under Section 143(2) for a belatedly filed return is valid.

Which sections of the Income-tax Act were involved?

Section 148,Section 143(2),Section 147,Section 144,Section 69,Section 56(2)(x)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA(SMC

Before: SUNIL KUMAR SINGHBRAJESH KUMAR SINGH

For Appellant: Shri Rajesh Malhotra, CA
For Respondent: Shri Anil Kumar, Sr (DR)
Hearing: 24.06.2026Pronounced: 18.08.2026

PER:BRAJESH KUMAR SINGH, A.M.

This appeal is directed against the impugned order dated 25.02.2026 passed in appeal No NFAC/2018-19/10348019 by the National Faceless Appeal Centre(NFAC) [hereinafter referred to as the “CIT(A) ] u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2019-20, wherein ld CIT(A) has dismissed assessee’s appeal.

2.

Brief facts of the case: The AO on perusal of the e-filing portal and 360 degree data of the assessee found that the assessee had not filed her return of income for AY 2019-20. The AO had information that the assessee had purchased an immovable property at a value of Rs. 6,30,000/- on 24.07.2018 which had a stamp duty value of Rs. 11,91,000/-. Accordingly, the AO issued not

The order continues below.

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