RAGHAVAN NAMBATH MENON,BENGALURU vs. ITO, WARD INTL. TAXATION 1(2), BMTC BUILDING, KORAMANGALA, BENGALURU

ITA 278/BANG/2025Status: DisposedITAT Bangalore06 February 2026AY 2015-16Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI KESHAV DUBEY (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 on April 19, 2022, for AY 2015-16, was barred by limitation. The six-year limitation period under the old regime 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, a non-resident, did not file an income tax return for AY 2015-16. The case was reopened under Section 147, and a notice under Section 148 was issued on April 19, 2022. The Assessing Officer added Rs. 10,12,160/- as unexplained cash credit under Section 68.

What were the issues?

Whether the notice issued under Section 148 for AY 2015-16 was barred by limitation given the amendments to Section 149 of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 149,Section 68

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

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

For Appellant: CA Suresh Muthukrishnan, A.R
For Respondent: Dr. Divya K.J., CIT D.R
Hearing: 12.11.2025Pronounced: 06.02.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. Income Tax Officer, Ward Intl. Taxation 1(2), Bangalore dated 17.12.2024 vide DIN & Order No. ITBA/AST/S/147/2024-25/1071274366(1) for the assessment year 2015-16. 2. The assessee has raised the following grounds of appeal:

Raghavan Nambath Menon, Bangalore Raghavan Nambath Menon, Bangalore 3. Brief facts of the case are that the assessee is a non- Resident and did not file h

The order continues below.

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