RAVINDRA KOVELAMUDI,GUNTUR vs. THE DCIT, CENTRAL CIRCLE-1, GUNTUR

ITA 391/VIZ/2026Status: DisposedITAT Visakhapatnam31 August 2026AY 2015-1617 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal condoned the delay and admitted additional grounds of appeal. It held that the reopening under Section 148 for AY 2013-14 was invalid, and proceedings under Section 153C for AY 2014-15 to 2016-17 were also invalid as they fell beyond the permissible six-year period without fulfilling the conditions of the fourth proviso to Section 153A(1).

What were the facts?

The assessee filed appeals against orders for AY 2013-14 to 2017-18 with a delay. The appeals involved challenges to reopening of assessment under Section 148 and proceedings under Section 153C, particularly concerning additions made on a protective basis.

What were the issues?

The key issues were the validity of reopening assessment under Section 148 and initiation of proceedings under Section 153C beyond the prescribed time limits and without fulfilling statutory conditions, as well as the sustainability of protective additions.

Which sections of the Income-tax Act were involved?

Section 148,Section 153C,Section 153A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Pronounced: 31.08.2026

PER SHRI VIJAY PAL RAO, VICE PRESIDENT :

These five appeals filed by the assessee are directed against five separate orders of Commissioner of Income Tax (Appeals)-3 [“Ld.CIT(A)”], Visakhapatnam for the A.Y.2013-14 to 2017-18 respectively. There is a delay of 6 days in filing all these appeals before

ITA 389/Viz/2026 to 393/Viz/2026 Ravindra Kovelamudi

the Tribunal. The assessee has filed petitions for condonation of delay, which are supported by affidavits o

The order continues below.

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