ITO, WARD -6(1), HYDERABAD vs. MAJJI RAMESH, HYDERABAD

ITA 787/HYD/2026Status: DisposedITAT Hyderabad17 June 2026AY 2020-217 pages
AI SummaryRemanded

What were the facts?

The assessee did not file a return of income for AY 2020-21. The AO reopened the case under Section 147 and issued a notice under Section 148. The assessee filed a return, and the AO made an addition under Section 69A. The CIT(A) allowed the assessee's appeal, quashing the assessment order due to an invalid notice under Section 148.

What did the Tribunal hold?

The Tribunal held that the retrospective insertion of Section 147A by the Finance Act, 2026, clarified that the Assessing Officer (JAO) had the authority to issue notices under Section 148. Therefore, the notice and consequential assessment order were valid.

What were the issues?

The primary issue was the validity of the notice issued under Section 148 by the Jurisdictional Assessing Officer, considering a High Court ruling and subsequent legislative amendments.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 147A,Section 69A,Section 151A,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘SMC‘ Bench, Hyderabad

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 11/06/2026

Per Madhusudan Sawdia, A.M.:

This appeal is filed by the Revenue, feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) (“Ld. CIT(A)”) dated 23.01.2026 for the A.Y. 2020-21. 2. The Revenue has raised the following grounds of appeal:

3

3.

The brief facts of the case are that Shri Majji Ramesh (“the assessee”) is an individual who had not filed any return of income for the A.Y. 2020-21 under section 139 of the Income-tax Act, 1961 for Assessment Year 2020-21. On the basis of information available with the Learn

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 147

All 48,773 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →