SAVITRI NEKKANTI,KAKINADA vs. INCOME TAX OFFICER, KAKINDA

ITA 187/VIZ/2026Status: DisposedITAT Visakhapatnam15 July 2026AY 2018-1920 pages
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What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under Section 147 of the Income Tax Act for AY 2018-19, issuing a notice under Section 148. The assessee argued that the notice was invalid as it was issued beyond three years and lacked proper approval from the prescribed authority as per Section 151.

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was issued without the mandatory approval of the specified authority under Section 151 of the Act for reopening beyond three years. Therefore, the assumption of jurisdiction by the AO was invalid.

What were the issues?

Whether the reassessment proceedings initiated by the AO were valid when the notice under Section 148 was issued beyond three years without obtaining approval from the authority specified under Section 151.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151,Section 69A,Section 292BC

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 assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, 1

ITA 187/VIZ/2026 Delhi (for short, “CIT(A)”), dated 23/12/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144B of

The order continues below.

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