PARWATI DEVELOPERS,RANCHI vs. ITO WARD 1(1) RANCHI, RANCHI

ITA 231/RAN/2026Status: DisposedITAT Ranchi10 July 2026AY 2017-185 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was issued with approval from the Principal Commissioner of Income Tax (PCIT) instead of the Principal Chief Commissioner of Income Tax (Pr. CCIT), as required by the amended Section 151 of the Act. Consequently, the notice was deemed void ab initio.

What were the facts?

The assessee challenged the reassessment proceedings initiated under Section 147 of the Income Tax Act. The primary ground for challenge was that the notice under Section 148 was issued beyond the prescribed limitation period and with improper approval.

What were the issues?

Whether the notice issued under Section 148 for reassessment was valid, considering the limitation period and the authority that granted the approval as per Section 151.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 149,Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Devesh Poddar, A.R
For Respondent: Shri Sandipan Khan, Sr.DR
Hearing: 10/07/2026Pronounced: 10/07/2026

PER: BENCH

1.

This is an appeal filed by the assessee against the order of the National Faceless Appeal Centre (NFAC), Delhi (in short, the ld. CIT(A) in Appeal No. NFAC/2016-17/10290804 dated 20/02/2026 for the A.Y. 2017-18. 2. Shri Devesh Poddar, ld. A.R. is represented on behalf of the assessee and Shri Sandipan Khan, ld. Sr.DR is represented on behalf of the revenue.

3.

At the outset, ld AR of the assessee has a challenged the proceedings u/s. 147 of the Act by issue of notice u/s.148 on the ground of limitation and approval U/s 151. He stated that as per Section 149(1)(a) read with section 151 of the Act, a notice under Section 148 can be issued upto three years from the e

The order continues below.

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