KAREMPUDI PADU PRIMARY AGRICULTURE COOPERATIVE SOCIETY LTD,GUNTUR vs. INCOME TAX OFFICER, WARD-1, GUNTUR

ITA 535/VIZ/2025Status: DisposedITAT Visakhapatnam21 August 2026AY 2018-1922 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment notices issued under Section 148 were invalid because the approval obtained from the Principal Commissioner of Income Tax was not in accordance with Section 151 of the Act, as more than three years had lapsed from the end of the assessment year. Consequently, the reassessment orders were quashed.

What were the facts?

The appeals were filed by various assessees against orders of the CIT(A)-NFAC. Delays in filing appeals were condoned by the Tribunal based on bonafide reasons. The primary issue revolved around the validity of reassessment notices issued under Section 148.

What were the issues?

The key legal issue was whether the reassessment proceedings initiated under Section 147/148 were valid when the approval for issuing the notice was obtained from an authority not specified under Section 151, especially when the notice was issued beyond three years from the end of the assessment year.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 250,Section 139(1),Section 148,Section 80P(2)(a)(i),Section 80AC,Section 148A,Section 151

AI-generated summary — verify with the full judgment below

IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM DB BENCH VISAKHAPATNAM

BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G. ACCOUNTANT MEMBER

Sl. ITA.No. Name of the Assessee Name of Order Appealed No. Respondent against the Order dated of the learned CIT(A)-NFAC & A.Y. 1. 248/Viz./2025 Konkuduru Primary ITO, Ward-1, Agricultural Cooperative Credit Kakinada. Dated Society Limited, Konkuduru- 13.03.2025 for 533 345. the AY 2018- PAN AABAK0376R 2019 2. 535/Viz./2025 Karempudipadu Primary ITO, Ward-1, Agriculture Cooperative Society Narasaraopet. Dated ltd., Karempudipada PACS 29.03.2025 for Mutluru, Atticherukuru, the AY 2018- Guntur. PIN 522002 2019 PAN AADAK7465M 3. 17/Viz./2026 Sai Sitaram Polavarapu, Eluru, ITO, Ward-1, Dated West Godavari District. PIN 534 Eluru 20.08.2025 for 007 the AY 2018- PAN BICPS4647A 2019 4. 156/Viz./2026 Naredla Jalareddy, Kothapalli ITO, Ward-3(1), Dated Post, Gampalagudem (M) Vijayawada 16.12.2025 for Krishna Dist. PIN 521 403 the AY 2018- PAN AGJPN1365N 2019 5. 575/Viz./2026 Venkata Ratnam Nargam, ITO, Ward-3(1), Dated Rayavaram, Krishna Dist. PIN – Vijayawada 20.02.2026 for 521 160 the AY 2018- PAN AKVPN7783J 2019

For Assessee : Sr

The order continues below.

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