ITS INDIA PVT. LTD,MUMBAI vs. THE ASSESSING OFFICER, MUMBAI

ITA 2374/MUM/2026Status: DisposedITAT Mumbai25 September 2026AY 2014-1515 pages
AI SummaryAllowed

What were the facts?

The assessee's assessment was reopened under Section 147. The Assessing Officer issued multiple notices under Section 148A(b) and passed the order under Section 148A(d) beyond the prescribed limitation period, considering the exclusion of time granted to the assessee.

What did the Tribunal hold?

The Tribunal held that the order passed under Section 148A(d) was barred by limitation due to the Assessing Officer issuing subsequent notices under Section 148A(b) to gain extension of time. Consequently, the assessment order was declared void ab initio.

What were the issues?

Whether the assessment order is void ab initio due to the invalid assumption of jurisdiction under Section 147, specifically concerning the timeliness of the order passed under Section 148A(d) and the validity of subsequent notices under Section 148A(b).

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 148,Section 148A,Section 149,Section 129

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, MUMBAI

Before: SHRI SAKTIJIT DEY & SHRI GIRISH AGRAWAL

Pronounced: 25.09.2026

Per Saktijit Dey, Vice President:

The captioned appeal by the assessee arises out of order dated 12.12.2025 passed by National Faceless Appeal Centre (NFAC), Delhi, pertaining to Assessment Year 2014-15. 2. In Ground No. 1, the assessee has challenged the validity of the assessment order passed under Section 147 read with Section 144B of the Income-tax Act, 1961 (in short, “the Act”).

3.

Since the issue raised in this ground is a purely legal a

The order continues below.

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