MARIA ROJALU POTHAKAMURI,NARSARAOPETA vs. INCOME-TAX OFFICER, WARD-1, NARSARAOPETA

ITA 587/VIZ/2025Status: DisposedITAT Visakhapatnam05 December 2025AY 2015-16Bench: Ld. CIT(A). Before Ld. CIT(A), assessee has raised various grounds challenging the assessment order. After considering the submissions of the assessee, Ld.CIT(A) dismissed the appeal of the assessee. 4. Being aggrieved by the order of the Ld. CIT(A), assessee filed an appeal before the Tribunal by raising following grounds of14 pages

AI SummaryAllowed

Facts

The assessee did not file a return of income for AY 2015-16. The Assessing Officer reopened the case under section 147 after issuing a notice under section 148A(b) and subsequently section 148, treating cash deposits of Rs. 54,80,000/- as unexplained under section 69A. The assessee's appeal to the CIT(A) was dismissed.

Held

The Tribunal held that the notice under section 148, issued on 07.04.2022 for AY 2015-16, was barred by limitation as per the unamended provisions of section 149(1)(b), as the six-year period expired on 31.03.2022. The reassessment proceedings were initiated without jurisdiction.

Key Issues

Whether the notice issued under section 148 for AY 2015-16 was valid and within the period of limitation, especially in light of the amended provisions of the Income Tax Act, 1961.

Sections Cited

147, 148, 148A(b), 69A, 139, 149(1)(b)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

आदेशकीप्रनतनलनपअग्रेनर्त/ Copy of the order forwarded to:- 1. निर्धाररती/The : Shri Maria Rojalu Pothakamuri, D.No.7- 159-47, Niraja Nilayam, Ravipadu Road, Assessee Narsaraopet 2. रधजस्व/ : The Income Tax Officer, Ward-1, Income The Tax Office, 12-9-22/A, 1st Floor, Prakash Revenue Nagar, Narsaraopet 3. The Principal Commissioner of Income Tax, Visakhapatnam 4. नवभधगीय प्रनतनिनर्, आयकर अपीलीय अनर्करण / DR,ITAT, Visakhapatnam. 5. The Commissioner of Income Tax 6. गधर्ाफ़धईल / Guard file

आदेशधिुसधर / BY ORDER

Sr. Private Secretary ITAT, Visakhapatnam.

MARIA ROJALU POTHAKAMURI,NARSARAOPETA vs INCOME-TAX OFFICER, WARD-1, NARSARAOPETA | BharatTax