CHANDRASHEKHAR PRASAD SINGH,PATNA, BIHAR vs. ITO WARD 4(1) PATNA , PATNA, BIHAR

ITA 159/PAT/2026Status: DisposedITAT Patna22 June 2026AY 2015-169 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment notice was issued beyond the period of limitation prescribed under Section 149(1)(b) of the Act, as the escaped income was less than Rs. 50 lakhs. Consequently, the assessment order was quashed.

What were the facts?

The assessee did not file a return for AY 2015-16. The AO initiated reassessment proceedings, issuing a notice under Section 148 on April 4, 2022, alleging significant cash deposits and fixed deposits. The assessee eventually filed a return and explained the sources, but the addition under Section 69A was confirmed by the CIT(A).

What were the issues?

The primary issue was the validity of reassessment proceedings initiated beyond the prescribed limitation period, particularly concerning the applicability of the extended period for escaped income below Rs. 50 lakhs.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH, PATNA

For Appellant: Shri Pawan Kumar, CA
For Respondent: Shri Mingma Sherpa, Sr. DR
Hearing: 03.06.2026Pronounced: 22.06.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals)m, National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “the Ld. CIT(A)] dated 22.09.2025, DIN & order No. ITBA/NFAC/S/250/2025- 26/1080986226(1) on the following grounds of appeal:

2 Chandrashekhar Prasad Singh “1. Invalidity of Reassessment Proceedings on Account of Limitation That on the facts and in the circumstances of the case and in law, the reassessment proceedings initiated by the Learned Assessing Officer and confirmed by the Lear

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 148

All 35,022 judgments and leading authorities on Section 148 →

Recent GST High Court judgments

Search GST case law →