SURYAPRABHA POOSAPATI,VISAKHAPATNAM vs. INCOME-TAX OFFICER, WARD-3(3), VISAKHAPATNAM

ITA 684/VIZ/2025Status: DisposedITAT Visakhapatnam17 July 2026AY 2015-1616 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was barred by limitation as per the first proviso to Section 149 of the Act. Consequently, the reassessment proceedings and the assessment order were quashed.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under Section 147 based on information about cash and time deposits. A notice under Section 148 was issued on April 3, 2022, for AY 2015-16, leading to an assessment order. The assessee appealed to the CIT(A), who dismissed it, and then appealed to the ITAT.

What were the issues?

The primary issue was whether the notice for reopening the assessment was issued within the prescribed time limit under Section 149, considering the amendments brought by the Finance Act, 2021.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Before: SHRI RAVISH SOOD, HON’BLE & SHRI OMKARESHWAR CHIDARA, HON’BLE

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (for short, “CIT(A)”), dated 04/11/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.

The order continues below.

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