JOINT COMMISSIONER OF INCOME TAX, (OSD), CIRLCE 1(1), RAIPUR, RAIPUR vs. RAJENDRA KUMAR AGRAWAL, RAIPUR, RAIPUR

ITA 253/RPR/2026Status: DisposedITAT Raipur16 July 2026AY 2017-189 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was issued beyond the three-year period and approved by the Principal Commissioner instead of the higher authorities specified in Section 151(ii). Therefore, the reassessment proceedings were vitiated and quashed.

What were the facts?

The Revenue appealed an order concerning assessment year 2017-18. The assessee contended that the notice under Section 148 was issued beyond the three-year period without proper approval from the competent authority as required by Section 151(ii).

What were the issues?

Whether the notice under Section 148 was validly issued beyond the three-year period, considering the required approval under Section 151(ii) of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 148,Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “DB”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY & SHRI AVDHESH KUMAR MISHRA

For Appellant: shri Praveen Khandelwal
For Respondent: Shri Piyush Tripathi, Sr. DR
Hearing: 14.07.2026Pronounced: 16.07.2026

PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the Revenue emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 02.01.2026 for the assessment year 2017-18 as per the grounds of appeal on record.

2.

The contention in law as per the application under Rule 27 of the ITAT Rules, 1963, assailed by the Ld. Counsel for the assessee is that the relevant assessment year is A.Y.2017-18 and

The order continues below.

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