THAMBIRAN SUBBIAH SUBRAMANIAN,THENI vs. ITO, WARD-1, THENI

ITA 1713/CHNY/2026Status: DisposedITAT Chennai07 August 2026AY 2018-1911 pages
AI SummaryAllowed

What were the facts?

The assessee did not file an income tax return. The Assessing Officer (AO) reopened the assessment after receiving information about the sale of immovable property and cash advance. The AO made an addition under Section 50C, and the CIT(A) provided partial relief.

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was invalid because it was issued beyond three years from the end of the relevant assessment year without obtaining approval from the Principal Chief Commissioner of Income Tax (PCCIT) as required by Section 151(ii). Consequently, the assessment proceedings were vitiated.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated by a notice under Section 148 issued beyond three years without the proper sanction from the competent authority as prescribed under Section 151(ii) of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 50C,Section 148,Section 148A,Section 151,Section 250,Section 263,Section 292BC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: SHRI GEORGE GEORGE K & MS. PADMAVATHY.S

For Respondent: Ms. D.Nithya, Addl. CIT

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 25.11.2025 for Assessment Year (AY) 2018-19. 2. The assessee is an individual and did not file the return of income for the year under consideration. The AO received information that the assessee

The order continues below.

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