BINU JOY KONDODY,CHANGANACHERRY vs. ITO, WARD 1, KOTTAYAM
What did the Tribunal hold?
The Tribunal held that the notice issued under Section 148 of the Income Tax Act, 1961, for AY 2015-16 was barred by limitation as it was issued beyond the prescribed period. Consequently, the reassessment proceedings and the consequent order were quashed.
What were the facts?
The Assessing Officer (AO) initiated reassessment proceedings against the assessee for AY 2015-16, alleging non-filing of return and cash deposits exceeding Rs. 50 lakhs. The AO added unexplained investment and interest income, leading to an assessed income of Rs. 17,82,926/-.
What were the issues?
The primary issue was whether the notice for reassessment under Section 148 was issued within the period of limitation prescribed by Section 149 of the Act, considering the amended provisions and the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.
Which sections of the Income-tax Act were involved?
Section 148,Section 148A,Section 149,Section 147,Section 144,Section 69,Section 115BBE
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, COCHIN BENCH : COCHIN (VIRTUAL HEARING
Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY
Heard together (2 matters)
Read from the judgment's own cause title. This page is filed under one of them.
PER KESHAV DUBEY, JUDICIAL MEMBER:
This appeal at the instance of the assessee is directed against the order of the ld. CIT(A)/NFAC dated 14.10.2025 vide DIN & Order No: ITBA/NFAC/S/250/2025-26/1081729928(1) passed u/s. 250 of the Income Tax Act, 1961 (in short “the Act”) for the AY 2015-16. ITANo.1041/Coch/2025 & SA No.3/Coch/2026 Binu Joy Kondody, Kottayam 2. The assessee has raised the followi
The order continues below.
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