KARNATAKA TELECOM DEPARTMENT EMPLOYEES CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), BLR, BANGALORE

ITA 1080/BANG/2025Status: DisposedITAT Bangalore31 December 2025AY 2016-17Bench: SHRI WASEEM AHMED (Accountant Member), SHRI SOUNDARARAJAN K. (Judicial Member)1 pages
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 prescribed by Section 149 of the Income Tax Act, as substituted by the Finance Act, 2021. Consequently, the reassessment proceedings were quashed.

What were the facts?

The assessee, a cooperative society, filed its return declaring NIL income. The case was reopened under Section 147, with the notice under Section 148 issued beyond the prescribed time limit. The assessee challenged the validity of the reassessment proceedings on the grounds of limitation.

What were the issues?

Whether the notice issued for reassessment under Section 148 was barred by limitation, rendering the entire reassessment proceedings invalid.

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, ‘A’ BENCH: BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K.

For Appellant: Shri PR Suresh, CA
For Respondent: Shri N Balusamy, JCIT-DR

PER WASEEM AHMED, ACCOUNTANT MEMBER

The present appeal is filed by the assessee against the order of the Ld. CIT(A) passed u/s 250 of the Act dated 13.03.2025 for the assessment year 2016-

17.2.

The assessee in the additional ground of appeal has challenged the validity of the assessment framed under section 147 of the Act on the ground that the order passed under section 148A(d) of the Act and the notice issued under section 148 of the Act is barred by the time.

3.

The assessee M/s Karnataka Telecom Department Employees Cooperative Society Limited is a cooperat

The order continues below.

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