MADHUBEN RAMNIK NANDU,GHATKOPAR WEST MUMBAI. vs. ITO, WARD 27(2)(1), MUMBAI, VASI RAILWAY STATION BUILDING, NAVI MUMBAI

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ITA 1361/MUM/2026Status: DisposedITAT Mumbai03 June 2026AY 2015-168 pages

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

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was issued beyond the permissible limitation period, as per the Supreme Court's decision in Union of India v. Rajiv Bansal. Consequently, the reassessment proceedings and the assessment order were quashed.

What were the facts?

The assessee's case was reopened for AY 2015-16, and a notice under Section 148 was issued on April 6, 2022. The assessee filed a return of income and contested the reassessment proceedings on legal grounds, including that the notice was time-barred.

What were the issues?

Whether the notice issued under Section 148 for AY 2015-16 was barred by limitation, and if so, whether the consequential reassessment proceedings and order are void ab initio.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 148,Section 148A,Section 149,Section 45,Section 54

AI-generated summary — verify with the full judgment below

Before: SHRI SAKTIJIT DEY & SHRI PRABHASH SHANKAR

For Appellant: Shri Rajesh Shah,AR
For Respondent: Shri Swapnil Choudhary, (Sr. DR)
Hearing: 29.04.2026Pronounced: 03.06.2026

आदेश की प्रतितलति अग्रेतिि/Copy of the Order forwarded to :

P a g e | 8 ITA No. 1361/Mum/2026 A.Y. 2015-16 Madhuben Ramnik Nandu 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आयुक्त / CIT 4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file. सत्यावपि प्रवि //True Copy// आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt. Registrar) आयकर अिीलीय अतधकरण/ ITAT, Bench, Mumbai. Details Date Initial Designation Sr. No. 1 Draft dictated on Sr.PS/PS 2 Draft Placed before author Sr.PS/PS 3 Sr.PS/PS Draft proposed & placed before the Second Member 4 Draft discussed/approved by JM/AM Second Member 5 JM/AM Approved Draft comes to the Sr.PS/PS 6 Order pronouncement on Sr.PS/PS 7 File sent to the Bench Clerk Sr.PS/PS 8 Sr.PS/PS Date on which the file goes to the Head clerk 9 Date on which file goes to the AR 10 Date of Dispatch of order

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