INCOME TAX OFFICER, WARD-1, NELLORE vs. VENKATA RAMANAMMA SAKAMURI, NELLORE

PDF · subscribers
ITA 482/HYD/2025Status: DisposedITAT Hyderabad14 November 2025AY 2018-1929 pages
AI SummaryDismissed

What did the Tribunal hold?

The CIT(A) quashed the notice under Section 148 because the approval for reopening the assessment, which was beyond three years from the end of the relevant assessment year, was obtained from the Principal Commissioner of Income Tax, whereas the law required approval from a higher authority (Principal Chief Commissioner or Chief Commissioner). The Tribunal concurred with this finding.

What were the facts?

The Assessing Officer (AO) reopened the assessment for AY 2018-19 based on substantial cash deposits and withdrawals, and liquor purchases, as the assessee had not filed a return. The AO issued a notice under Section 148, and subsequently made additions, leading to an appeal by the assessee.

What were the issues?

Whether the reopening of assessment beyond three years was valid without the approval of the specified higher authority as per Section 151 of the Act.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(2)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad

For Appellant: Ms. Payal Gupta, Sr. AR

आदेशक���त�ल�पअ�े�षत/ Copy of the order forwarded to:- 1. �नधा�रती/The Assessee : Venkata Ramanamma Sakamuri, 1-18, Tikkavaram Post, Pallavolu, Marripadu Mandal, Nellore, Andhra Pradesh-524312. 2. राज�व/ The Revenue : Income Tax Officer, Ward-1, D.No. 27-1- 114, 2nd Floor, Manishankar Spectrum, Opp. Children Park, Aditya Nagar, Nellore, Andhra Pradesh-524002. 3. The Principal Commissioner of Income Tax, Tirupati. 4. �वभागीय��त�न�ध, आयकरअपील�यअ�धकरण /DR,ITAT, Hyderabad. 5. The Commissioner of Income Tax 6. गाड�फ़ाईल / Guard file

आदेशानुसार / BY ORDER

Sr. Private Secretary ITAT, Hyderabad.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →