ROHIT MANCHAND,DELHI vs. ITO WARD 5(3)(2), GAUTAM BUDH NAGAR

ITA 5124/DEL/2025Status: DisposedITAT Delhi12 February 2026AY 2012-13Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI RAJ KUMAR CHAUHAN (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the Section 148 notice was not served on the assessee and the reassessment proceedings were initiated beyond the six-year period. Therefore, the entire reassessment process was void ab initio.

What were the facts?

The Assessing Officer initiated reassessment proceedings under Section 148 based on AIR information about the sale of an immovable property. The assessee did not comply with notices, leading to an ex-parte assessment. The assessee appealed, arguing that the Section 148 notice was never served and the reassessment was initiated beyond the limitation period.

What were the issues?

Whether reassessment proceedings initiated without proper service of notice under Section 148 are valid, and whether proceedings initiated beyond the prescribed limitation period are sustainable.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 144,Section 139,Section 54,Section 50C

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Cases cited in this judgment(6)Show list

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Income Tax Appellate Tribunal, DELHI BENCHES ‘E’: NEW DELHI.

Before: SHRI S. RIFAUR RAHMAN & SHRI RAJ KUMAR CHAUHAN

For Appellant: CA &
For Respondent: Ms. Ankush Kalra, Sr.DR
Hearing: 11.12.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

This appeal is filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to ‘ld. CIT(A)’) dated 18.08.2025 for AY 2012-13. 2. Brief facts of the case are, the Assessing Officer issued notice u/s 148 of the Income Tax Act, 1961 (in short ‘Act’) on the basis of information available with him that assessee had sold an immovable property for total

2 consideration of Rs.1.83 crores during the financial year 2011-12 related to assessment year 2012-13 on the basis of Non-PAN based AIR information.

3.

On the basis of

The order continues below.

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