ARUN DURAISWAMY,MYSORE, KARNATAKA vs. ITO, INTL. TAXATION WARD 1(1), BANGALORE

ITA 193/BANG/2025Status: DisposedITAT Bangalore16 February 2026AY 2015-16Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI KESHAV DUBEY (Judicial Member)33 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 on April 29, 2022, for AY 2015-16 was invalid and barred by limitation. The six-year limitation period under the old regime for AY 2015-16 expired on March 31, 2022, and the first proviso to the substituted Section 149(1) acts as a statutory bar.

What were the facts?

The assessee did not file a return for AY 2015-16 as he had no taxable income in India. The Assessing Officer (AO) reopened the case under Section 147, issuing a notice under Section 148 on April 29, 2022. The assessee challenged the validity of the notice on grounds of jurisdiction and limitation.

What were the issues?

The primary issue was whether the reassessment notice issued under Section 148 was within the prescribed time limits, considering the amendments to Sections 147 to 151 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149,Section 144,Section 69,Section 69C

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Income Tax Appellate Tribunal, “A’’BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

For Appellant: CA Deepak Gunashekar, A.R
For Respondent: Dr. Divya K.J, CIT D.R
Hearing: 22.01.2026Pronounced: 16.02.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of Income Tax Officer, Ward-Intl. Taxation 1(1),Bengaluru dated 12/12/2024 vide DIN and Order No: ITBA/AST/S/147/2024- 25/1071150608(1) passed u/s. 147 r.w.s 144 of the Income Tax Act, 1961 (in short “the Act”) for the AY 2015-16. 2. The assessee has raised the following grounds of appeal: -

The appellant objects to the order of the Ld. AO u/s. 147 in pursuance of the directions of the Dispute Resolution Panel order on the grounds that:

IT(IT)A No.193/Bang/2025 Arun Duraiswamy, Mysore Grounds Raised Tax Effec

The order continues below.

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