UPPALAPATI SUBBALAKSHMI,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, WARD-2(1), VISAKHAPATNAM

ITA 78/VIZ/2026Status: DisposedITAT Visakhapatnam17 July 2026AY 2016-178 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A) erred by not adjudicating the legal issues raised by the assessee regarding the validity and limitation of the notice issued under Section 148. The matter was restored to the CIT(A) for adjudication of these specific grounds.

What were the facts?

The Assessing Officer initiated reassessment proceedings under Section 147 based on information about substantial financial transactions by the assessee who had not filed a return. The CIT(A) set aside the assessment order to the AO for fresh assessment, citing a proviso to Section 251(1)(a).

What were the issues?

Whether the CIT(A) was justified in setting aside the assessment without deciding the legal issues of limitation and validity of the notice issued under Section 148.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144,Section 144B,Section 251(1)(a)

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 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (for short, “CIT(A)”), dated 12/11/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147

ITA 78/VIZ/2

The order continues below.

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