PITTALA BHASKARA RAO,GUNTUR vs. INCOME TAX OFFICER, WARD-1(1), GUNTUR, GUNTUR

ITA 778/VIZ/2026Status: DisposedITAT Visakhapatnam21 August 2026AY 2015-169 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Income-tax Act, 1961, was barred by limitation as it was issued beyond the prescribed period under the unamended provisions. Therefore, the reassessment order was quashed.

What were the facts?

The assessee did not file an income tax return for AY 2015-16. The Assessing Officer (AO) reopened the case under Section 147 based on information about cash deposits. The AO treated Rs. 48,34,600 as unexplained money and completed the assessment. The assessee appealed, and the CIT(A) directed the AO to provide an opportunity to submit details.

What were the issues?

Whether the notice issued under Section 148 of the Income-tax Act, 1961, for AY 2015-16 was barred by limitation, considering the unamended and amended provisions of Section 149.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 149,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Pronounced: 21.08.2026

PER SHRI MANJUNATHA G., ACCOUNTANT MEMBER:

ITA 629/Viz/2026, A.Y.2015-16 This appeal is filed by the Assessee against the order of Commissioner of Income Tax(Appeals) [“Ld.CIT(A)”], National Faceless 1

ITA 629/Viz/2026 & 778/Viz/2026 Thommandru S

The order continues below.

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