PENTYALA MADHAVI,HYDERABAD vs. INCOME TAX OFFICER, WARD-12(1), HYDERABAD

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ITA 392/HYD/2025Status: DisposedITAT Hyderabad07 November 2025AY 2015-2016Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)11 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 on 29-04-2022 for AY 2015-16 was barred by limitation. Relying on the Supreme Court's decision in Union of India vs. Rajeev Bansal, it was affirmed that notices issued after 01-04-2021 for AY 2015-16 are invalid as the time limit under the old regime and TOLA had expired. Consequently, the assessment order passed by the AO was quashed.

What were the facts?

The assessee did not file an income tax return for AY 2015-16. The AO reopened the assessment under Section 147 by issuing a notice under Section 148 on 29-04-2022, based on information about banking transactions aggregating Rs. 65.47 lakhs. Additions were made for unexplained cash deposits under Section 69A and agricultural income treated as income from other sources, which were sustained by the CIT(A).

What were the issues?

Whether the reopening notice issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2015-16 on 29-04-2022 was barred by limitation, rendering the subsequent assessment proceedings invalid.

Which sections of the Income-tax Act were involved?

Section 139,Section 148,Section 147,Section 142(1),Section 144,Section 69A,Section 148A,Section 148A(d),Section 149(1)(b),Section 144B

AI-generated summary — verify with the full judgment below

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Income Tax Appellate Tribunal, Hyderabad “B- SMC” Bench, Hyderabad

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-

1. 1. निर्धाररती/The Assessee : Pentyala Madhavi, 8-2-674/B/3/1/101, Ushassu Apartments, Road No.12, Banjarahills – 500034, Hyderabad, Telangana. 2. रधजस्व/ The Revenue : The Income Tax Officer, Ward – 12(1), Hyderabad.

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