HEMALI BABUBHAI KATORIWALA,SURAT vs. ITO, WARD 1(2)(1), SURAT

ITA 672/SRT/2025Status: DisposedITAT Surat10 August 2026AY 2014-1523 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were barred by limitation as the notice under Section 148 was issued beyond the permissible time limits prescribed by law and Supreme Court decisions. Consequently, the assessment order was quashed.

What were the facts?

The assessee's case was reopened for AY 2013-14 based on information of escaped income. A notice under Section 148 was issued, and subsequent reassessment order was passed. The CIT(A) dismissed the appeal for non-prosecution.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated after the prescribed time limits, considering the amendments and Supreme Court rulings on reassessment notices.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149,Section 69A,Section 68,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Suresh K. Kabra, CA
For Respondent: Shri J.K. Chandnani, CIT (DR) &, Shri Ashish Kumar, Sr. DR
Hearing: 30.07.2026Pronounced: 10.08.2026

Heard together (4 matters)

ITA No.671/SRT/2025
ITA No.673/SRT/2025
ITA No.675/SRT/2025
ITA No.677/SRT/2025

Read from the judgment's own cause title. This page is filed under one of them.

Per Bench:

This bunch of eight (8) appeals, consisting of four (4) quantum-appeals and four (4) penalty-appeals, is filed by same assessee; the counsels

ITA No.670/SRT/2025 (AY: 2013-14) & ors. Hemali Babubhai Katoriwala representing in all matters are same and the issues are also identical, hence they are being disposed of by this consolidated order for the sake of convenience.

2.

There is a delay of 47 days in filing all these appeals. H

The order continues below.

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