ABHISHEK AGRAWAL, JHANJGIR-CHAMPA,JHANJGIR-CHAMPA vs. ITO, WARD-2(1), BILASPUR, BILASPUR

ITA 538/RPR/2026Status: DisposedITAT Raipur15 July 2026AY 2014-1510 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was time-barred and void ab initio, as the escaped income was less than Rs. 50 lakhs and the notice was issued after the expiry of the time limit as per the prevailing CBDT instructions and Supreme Court decisions.

What were the facts?

The assessee's appeal concerns assessment year 2014-15, where the Assessing Officer recorded income escaping assessment at Rs. 12,00,045/-. A notice under Section 148 was issued on April 1, 2021.

What were the issues?

Whether the reassessment notice issued under Section 148 was valid considering the amount of escaped income and the date of issuance in light of the amended provisions of Section 149 and relevant CBDT instructions.

Which sections of the Income-tax Act were involved?

Section 148,Section 149

AI-generated summary — verify with the full judgment below

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

Before: SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Veekaas S Sharma, CA
For Respondent: Shri Piyush Tripathi, Sr. DR
Hearing: 14.07.2026Pronounced: 15.07.2026

PER PARTHA SARATHI CHAUDHURY, JM The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 24.04.2026 for the assessment year 2014-15 as per the grounds of appeal on record.

2.

The contention in law as assailed by the Ld. Counsel for the assessee in this case is that as per CBDT Instruction No.1/2022, dated 11.05.2022, the CBDT has, inter alia, stated at Para 7.1 of

The order continues below.

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