VINCENT JOSEPH PEREIRA,MUMBAI vs. ITO 42(1)(5), MUMBAI

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ITA 3454/MUM/2026Status: DisposedITAT Mumbai18 June 2026AY 2015-167 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was barred by limitation as it was issued beyond the period of six years from the end of the relevant assessment year. Consequently, the assessment framed under Section 147 was quashed.

What were the facts?

The assessee's case was reopened for AY 2015-16, with a notice under Section 148 issued on 20.04.2022. The assessment was framed on a best judgment basis, including short-term capital gains and accommodation entries.

What were the issues?

Whether the notice issued under Section 148 for reopening the assessment for AY 2015-16 was barred by limitation as per the provisions of Section 149 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “F” BENCH, MUMBAI

Before: HON’BLE SHRI PAWAN SINGH, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

आदेश की प्रनिनलनप अग्रेनर्ि /Copy of the Order forwarded to : 1. अपीलाथी/Appellant 2. प्रत्यथी/Respondent 3. आयकरआयुक्त/CIT 4. ववभागीयप्रवतवनवि/DR 5. गार्डफाईल/GF

ASSISTANT REGISTRAR

ITAT MUMBAI

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