RAMDAS GAVTYA WAGHMARE,PANVEL vs. ASSESSING OFFICER, PANVEL

ITA 1284/PUN/2026Status: DisposedITAT Pune24 September 2026AY 2015-201610 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under section 148 was beyond the limitation period and therefore bad in law. Consequently, the reassessment order was quashed.

What were the facts?

The assessee filed an appeal against the reassessment order for AY 2015-16. The notice under section 148 was issued on 05.04.2022, which was beyond the limitation period of 31.03.2022.

What were the issues?

Whether the notice issued under section 148 for AY 2015-16 was time-barred, considering the proviso to section 149(1) and the exclusion of time allowed for response to the section 148A notice.

Which sections of the Income-tax Act were involved?

Section 148,Section 149(1),Section 148A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “B”, PUNE

Before: MS. ASTHA CHANDRA & SHRI Dr. DIPAK P. RIPOTE

For Appellant: Shri Anand Bagade and Shri Suresh Kumar Gandher
For Respondent: Ms. Bhavya. I.V., Jt. CIT

PER Dr. DIPAK P. RIPOTE, A.M : This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), NFAC, Delhi [Ld.CIT(A)], passed u/s. 250 of the Income Tax Act, 1961 („the Act‟) for AY 2015-16 on 10.09.2025, emanating from the Assessment Order u/s 147 r.w.s. 144 of the Act, dated 08.02.2024. 2. There was a delay of 110 days in filing of the appeal before this Tribunal. The assessee filed an affidavit explaining the reasons for delay. We have perused the affidavit and convinced that there was sufficient cause for delay. Substantial justice is more important than procedural delay. No assessee is going to gain

The order continues below.

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