ABDUL SALAM MOHAMED YASIN,MUMBAI vs. DCIT CIRCLE 17(1), MUMBAI

ITA 7502/MUM/2025Status: DisposedITAT Mumbai21 January 2026AY 2017-18Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was issued beyond the permissible limitation period as per the Supreme Court's decision in Rajeev Bansal. Furthermore, the mandatory sanction under Section 151(ii) was granted by an incompetent authority, rendering the entire reassessment proceedings void ab initio.

What were the facts?

The assessee challenged the validity of reassessment proceedings initiated under Section 147 read with Section 144B of the Income-tax Act. The primary grounds for challenge were the invalidity of the notice issued under Section 148 due to being time-barred and lack of proper sanction under Section 151(ii).

What were the issues?

Whether the notice issued under Section 148 for reassessment was barred by limitation, and whether the sanction obtained under Section 151(ii) was valid.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149,Section 151(ii),Section 144B

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Income Tax Appellate Tribunal, ‘A’ BENCH

Before: SHRI AMIT SHUKLA & SHRI MAKARAND VASANT MAHADEOKAR

For Appellant: Shri Hitesh Jain
For Respondent: Shri Surendra Mohan, Sr
Hearing: 19/01/2026Pronounced: 21/01/2026

PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against order dated 13.10.2025 passed by the National Faceless Appeal Centre, Delhi, for the quantum of assessment framed under section 147 read with section 144 of the Income-tax Act, 1961, for the assessment year 2017–18. 2 Abdul Salam Mohamed Yasin

2.

In the grounds of appeal, the assessee has, inter alia, challenged the validity of the reopening under section 148 and the consequential reassessment order passed under section 147 read with section 144B on various juri ictional and legal grounds.

3.

At the threshold, it has been submitted that the notice issued under section 148 of the Act itself is barred by

The order continues below.

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