SAMBA SIVA RAO BOBBA,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-3(1), VIJAYAWADA

ITA 73/VIZ/2026Status: DisposedITAT Visakhapatnam17 July 2026AY 2015-1617 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under section 148 of the Act was barred by limitation as per the first proviso to section 149 of the Act. Consequently, the assessment order passed by the AO was quashed for want of valid assumption of jurisdiction.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under section 147 of the Income Tax Act, 1961, for AY 2015-16, issuing a notice under section 148. The AO made an addition of Rs. 31,45,000/- as unexplained cash deposits. The assessee appealed to the CIT(A) without success.

What were the issues?

The key issue was whether the notice issued under section 148 for reassessment was within the prescribed time limit, considering the amendments to section 149 of the Act.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 69A,Section 148,Section 149

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 05/12/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144B of the Income Tax Act, 1961 (for short, “the

The order continues below.

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