SHREE SUPRINIT TRADINVEST PRIVATE LIMITED,AHMEDABAD vs. ITO WARD 4 (1) (3) AHMEDABAD, AHMEDABAD

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ITA 1935/AHD/2025Status: DisposedITAT Ahmedabad22 April 2026AY 2015-1610 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notices issued under Section 148 of the Act were beyond the 'surviving time' as per the Supreme Court's decisions in Ashish Agrawal and Rajeev Bansal. Consequently, the reopening notices and subsequent reassessment proceedings were quashed.

What were the facts?

The assessee filed appeals against reassessment orders for AYs 2015-16, 2016-17, and 2017-18. The primary issue was the validity of the reopening of assessments under Section 147 of the Income Tax Act.

What were the issues?

Whether the reassessment notices issued under Section 148 were validly issued within the prescribed time limits, considering the extensions provided by the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020.

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, AHMEDABAD “D” BENCH

Before: Shri T. R. Senthil Kumar & Shri. Narendra Prasad Sinha

आदेश की प्रतितिति अग्रेतिि / Copy of Order Forwarded to:- 1. Assessee 2. Revenue 3. Concerned CIT 4. CIT (A) 5. DR, ITAT, Ahmedabad 6. Guard file. By order/आदेश से, उि/सहायक िंजीकार आयकर अिीिीय अतिकरण, अहमदाबाद

10 ITA No: 1935, 1936 and 1937/Ahd/2025 Assessment Year: 2015-16, 2016-17, 2017-18

Strengthened preparation & delivery of orders in the ITAT 1) Date of dictation 15/04/2026 2) Date on which the typed draft is placed before the Dictating 16/04/2026 Member & Other Member 3) Date on which the approved draft comes to the Sr. P.S./P.S. /04/2026 4) Date on which the fair order is placed before the Dictating 22 /04/2026 Member for pronouncement 5) Date on which the fair order comes back to the Sr. P.S./P.S. /04/2026 6) Date on which the file goes to the Bench Clerk /04/2026 7) Date on which the file goes the Head Clerk 8) Date on which the file goes to the Assistant Registrar for signature on the order 9) Date of Dispatch of the order

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