VIJAYBHAI DAYABHAI MARVANIYA,MORBI vs. ITO WARD 1, MORVI

ITA 740/RJT/2026Status: DisposedITAT Rajkot25 August 2026AY 2017-186 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Act on 28.06.2022 was barred by limitation. Consequently, the reassessment proceedings were invalid, and the assessment order was quashed.

What were the facts?

The assessee's return of income for AY 2017-18 was assessed under Section 147 after the department received information about an undisclosed investment of Rs. 45,00,000. Reassessment proceedings were initiated, and a notice under Section 148 was issued on 28.06.2022.

What were the issues?

The primary issue was whether the notice issued under Section 148 of the Income-tax Act, 1961, was within the permissible period of limitation as per the directions of the Supreme Court in Union of India v. Ashish Agarwal.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Rajendra Singhal, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 24/08/2026Pronounced: 25/08/2026

Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2018-19, is directed against the order under section 250 of the Income-tax Act, 1961 [hereinafter referred to as ‘the Act’] passed by the National Faceless Appeal Centre [hereinafter referred to as ‘NFAC’], dated 10.03.2026, which in turn arises out of an order passed by assessing officer u/s. 147 of the Act, dated 25.05.2023. 02. Brief facts of the case are that the assessee filed its return of

The order continues below.

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