VIJBHUKHANDAS & BROS,SURAT vs. INCOME TAX OFFICER 2(1)(1), SURAT, SURAT

ITA 459/SRT/2026Status: DisposedITAT Surat10 August 2026AY 2017-187 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was time-barred by 51 days, following the Supreme Court's decision in Union of India v. Rajeev Bansal. Consequently, the reassessment proceedings were quashed.

What were the facts?

The assessee filed an appeal belatedly. The Assessing Officer issued a notice under Section 148, which the assessee argued was time-barred based on a Supreme Court judgment. The Tribunal condoned the delay in filing the appeal.

What were the issues?

The primary issue was the validity of the notice issued under Section 148 of the Income Tax Act, 1961, concerning the time limit for reassessment proceedings.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 144B,Section 148A,Section 149

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Sapnesh Sheth, Advocate
For Respondent: Shri Ajay Uke, Ld. Sr. DR
Hearing: 14/05/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2017-18, is directed against the order passed under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 22.08.2025 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) [in short ‘Ld.CIT(A)’] which in turn arises out of an assessment order passed by the Assessing Officer (in short ‘AO’) u/s 147 read with section 144B of the Act, d

The order continues below.

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