NAREDLA JALAREDDY,KOTHAPALLI vs. INCOME TAX OFFICER, WARD-3(1), VIJAYAWADA
What did the Tribunal hold?
The Tribunal held that the reassessment notices issued under Section 148 were invalid because the approval for reopening was obtained from an authority not specified under Section 151 of the Income Tax Act, especially when the notice was issued beyond three years from the end of the assessment year.
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 the validity of reassessment proceedings initiated under Section 148 due to improper approval under Section 151, and whether the claim for deduction under Section 80P was correctly disregarded.
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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