IMPRESSIVE TRADING PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

ITA 7298/MUM/2025Status: DisposedITAT Mumbai11 February 2026AY 2013-1418 pages
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What did the Tribunal hold?

The Tribunal held that the notices issued under Section 148 of the Income Tax Act were barred by limitation, as they were issued beyond the 'surviving period' as interpreted by the Supreme Court in the Rajeev Bansal case. Consequently, the reassessment orders were deemed void ab initio.

What were the facts?

The assessee's assessments were reopened based on information suggesting bogus accommodation entry activities and circular movement of funds. Additions were made on a percentage basis of credit entries in the bank account as undisclosed commission.

What were the issues?

The primary issue was the validity of notices issued under Section 148 for reopening assessments, specifically whether they were time-barred considering the 'surviving period' and subsequent procedural requirements.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 148A,Section 151A

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Cases cited in this judgment(2)Show list

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Page 2 ITA No. 7298, 7299& 7300/Mum/2025 A.Y. 2013-14, 2014-15 & 2015-16 Impressive Trading Pvt Ltd., Mumbai [A.Ys.] 2013-14, 2014-15 & 2015-16.Since the issues are common and also the fact that appeals were heard together, they are being taken up together for adjudication vide this composite order for the sake of brevity. We take up appeal in ITA No. 7298/Mum/2025 first.

2.

The grounds of appeal are as under:-

1.

On the facts and under the circumstances of the case and in law the Ld. Commissioner of Income Tax (Appeals) has erred in confirming the reopening of the assessment by the ld. A.O. merely on the basis of vague information received from the Investigation Wing and no independent inquiry was made by him.

2.

On the facts and under the circumstances of the case and in law the Ld. Commissioner of Income Tax (Appeals) has erred in confirming the conclusion of the Ld. A.O. that income chargeable to tax has escaped assessment.

3.

On the facts and under the circumstances of the case and in law the Ld. Commissioner of Income Tax (Appeals) has erred in confirming the reopening of the assessment for this year 2013-14 by the Ld. A.O. ignoring the fact that last dat

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