ARIMILLI RAMA KRISHNA,WEST GODAVARI DIST vs. ACIT, CIRCLE-1, RAJAHMUNDRY

ITA 639/VIZ/2025Status: DisposedITAT Visakhapatnam18 March 2026AY 2014-15Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI OMKARESHWAR CHIDARA, HON'BLE (Accountant Member)12 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the AO failed to issue a notice under section 143(2) within the prescribed time limit. Consequently, the assessment order was quashed.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under section 147 and made an addition of Rs. 2,14,97,772/- as deemed dividend under section 2(22)(e). The assessee challenged the reassessment proceedings and the addition.

What were the issues?

Whether the reassessment proceedings are valid when a notice under section 143(2) is not issued within the statutory time limit, and if section 292BB can cure such a defect.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(2),Section 2(22)(e),Section 292BB

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(15)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, VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM

Before: SHRI RAVISH SOOD, HON’BLE & SHRI OMKARESHWAR CHIDARA, HON’BLE

For Appellant: Shri G.V.N.Hari, Advocate
For Respondent: Shri K. Prasad, Sr. DR
Pronounced: 18.03.2026

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 18.09.2025, which in turn arises from the order passed by I.T.A.No.639/VIZ/2025 Arimilli Rama Krishna the Assessing Of

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

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

Recent GST High Court judgments

Search GST case law →