INCOME TAX OFFICER, WARD2(1), GUNTUR vs. NAGARJUNA CHOWDARY MALLAVARAPU, GUNTUR

ITA 807/VIZ/2025Status: DisposedITAT Visakhapatnam15 July 2026AY 2015-167 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(A) had erred by quashing the proceedings solely on the ground of limitation without considering the full ratio of the Supreme Court judgments in Ashish Agarwal and Rajeev Bansal. The Tribunal held that the reassessment proceedings should be examined in light of the substituted provisions and the conditions laid down by the Supreme Court.

What were the facts?

The Revenue appealed an order by the CIT(A) that quashed reassessment proceedings for AY 2015-16, holding the notice under Section 148 to be time-barred. The AO had initiated reassessment based on significant bank credits, treating an earlier notice as a deemed notice under Section 148A(b) following Supreme Court directions.

What were the issues?

Whether the CIT(A) was justified in quashing reassessment proceedings on limitation without a complete examination of the Supreme Court's pronouncements on reassessment notices issued after April 1, 2021, and the applicability of amended Section 149.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH,

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

PER RAVISH SOOD, JM: The present appeal filed by the Revenue is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, [for short, “CIT(A)] for the assessment year 2015-16, which in turn arises

ITA 807/VIZ/2025 from the order passed by the Assessing

The order continues below.

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