SUB MAJOR SUB BHADAURIA,AGRA vs. ITO WARD, 1(1)(2), AGRA, AGRA

ITA 469/AGR/2026Status: DisposedITAT Agra12 August 2026AY 2016-176 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Act on 30.07.2022 was barred by limitation, as it was issued beyond the period prescribed by 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. A notice under Section 148A(b) was issued, followed by a reply from the assessee. Subsequently, an order under Section 148A(d) and a notice under Section 148 were issued.

What were the issues?

The key issue was whether the notice for reassessment was issued within the period of limitation, considering the impact of Supreme Court judgments on the procedural timelines for reopening assessments.

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 (SMC

Before: SUNIL KUMAR SINGH & BRAJESH KUMAR SINGH

For Appellant: Shri Pankaj Gargh, Adv
For Respondent: Shri Anil Kumar, Sr (DR)
Hearing: 23.07.2026Pronounced: 12.08.2026

PER: BRAJESH KUMAR SINGH, A.M. This appeal has been preferred against the impugned order dated 16.03.2026 passed in Appeal No NFAC/2015-16/10269489 by the ld Commissioner of Income Tax, 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. 2016-17, wherein ld CIT(A) has dismissed the appeal.

2.

At the very outset, we notice that assessee has raised as many as 06 grounds under this second appeal. Ld AR has submitted that according to the legal ground no. 1 & 2, 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

The order continues below.

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