ITO 13(2)(1), MUMBAI, MUMBAI vs. SSV MARKETING PRIVATE LIMITED, MUMBAI

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ITA 3619/MUM/2025Status: DisposedITAT Mumbai29 May 2026AY 2015-1612 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reassessment notice issued for AY 2015-16 after April 1, 2021, was time-barred as per the Supreme Court's decision in Union of India v. Rajeev Bansal. Consequently, the assessment order was quashed.

What were the facts?

The Revenue appealed against the CIT(A)'s order quashing the assessment order. The assessee had challenged the validity of the reassessment notice under Section 148, claiming it was issued beyond the limitation period.

What were the issues?

Whether the reassessment notice issued under Section 148 for AY 2015-16 was valid and within the prescribed limitation period.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 148,Section 149,Section 148A

AI-generated summary — verify with the full judgment below

Before: SHRI SAKTIJIT DEY & SHRI PRABHASH SHANKAR

For Appellant: Shri Satish Mody, Adv
For Respondent: Shri Subhas K.R., CIT DR
Hearing: 20.04.2026Pronounced: 29.05.2026

आदेश की प्रतितलति अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आयुक्त / CIT 4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai

P a g e | 12 ITA No. 3619/Mum/2025 A.Y. 2015-16 SSV Marketing Private Limited 5. गार्ड फाईल / Guard file. सत्यावपि प्रवि //True Copy// आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt. Registrar) आयकर अिीलीय अतधकरण/ ITAT, Bench, Mumbai.

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