SHOEB AHMAD & COMPANY,SHAHAGANJ S.O, AGRA vs. INCOME-TAX OFFICER, WARD 1(1)(2), AGRA, SANJAY PLACE, AGRA

ITA 316/AGR/2026Status: DisposedITAT Agra12 August 2026AY 2014-20156 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 on 31.07.2022 was barred by limitation, as per the Supreme Court's decision in Union of India v. Rajeev Bansal. Consequently, the reassessment proceedings were quashed.

What were the facts?

The assessee's case was reopened under Section 147/148 of the Income Tax Act. The initial notice under the old regime was issued on 24.06.2021. Following Supreme Court decisions, a notice under Section 148A(b) was issued on 24.05.2022, with a reply filed on 13.06.2022. Subsequently, an order under Section 148A(d) and a notice under Section 148 were issued on 31.07.2022.

What were the issues?

The primary issue was whether the notice for reassessment issued under Section 148 was within the period of limitation, considering the various pronouncements of the Supreme Court regarding the reopening of assessments during the period affected by the pandemic and subsequent amendments.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA (DB

Before: SUNIL KUMAR SINGHBRAJESH KUMAR SINGH

For Appellant: Shri Deependra Mohan, CA
For Respondent: Smt Sangeeta Yadav, CIT (DR)
Hearing: 09.07.2026Pronounced: 12.08.2026

PER:BRAJESH KUMAR SINGH, A.M.

This appeal is directed against the impugned order dated 31.03.2026 passed in appeal No NFAC/2013-14/10273271 by the ld. Commissioner of Income Tax (Appeals)/NFAC (DELHI) (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. 2014-15, wherein ld CIT(A) has dismissed assessee’s appeal ex-parte.

2.

At the very outset, we notice that assessee has raised as many as 11 grounds under this second appeal. Ld AR has submitted that according to the legal ground no. 2 & 3, the assumption of juri iction for reassessment u/s 147/148 of the Act is barred by limitation in view of law laid down by Hon’ble Supreme Co

The order continues below.

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