S 1284 THATHAIYANGARPATTY PACCS LTD.,NAMAKKAL vs. ITO, WARD-2,, NAMAKKAL

ITA 3172/CHNY/2025Status: DisposedITAT Chennai04 March 2026AY 2018-19Bench: SHRI GEORGE GEORGE K, VICE PRESIDENTAND MS. PADMAVATHY.S (Accountant Member)1 pages
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What did the Tribunal hold?

For AY 2017-18, the appeal was allowed for statistical purposes, remanding the issue to the CIT(A) for fresh adjudication. For AY 2018-19, the Tribunal held that the notice under Section 148 was invalid due to the incorrect sanctioning authority, thus quashing the assessment.

What were the facts?

For AY 2017-18, the assessee's appeal was remitted back to the CIT(A) for fresh consideration due to insufficient documentation regarding additions made under Section 69A. For AY 2018-19, the assessee challenged the validity of the notice issued under Section 148 due to improper sanctioning authority.

What were the issues?

Whether the addition made under Section 69A for AY 2017-18 requires fresh consideration by the CIT(A). Whether the notice issued under Section 148 for AY 2018-19 was invalid due to the sanctioning authority not complying with Section 151.

Which sections of the Income-tax Act were involved?

Section 69A,Section 80P,Section 139(1),Section 148,Section 148A,Section 149,Section 151,Section 250

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI GEORGE GEORGE KAND MS. PADMAVATHY.S

Hearing: 20.02.2026Pronounced: 04.03.2026

PER PADMAVATHY.S, A.M: These appeals by the assessee are against the separate orders of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 29.07.2025 for Assessment Year (AY) 2017- 18 dated 15.07.2025 for A.Y 2018-19. ITA Nos.3171 & 3172/Chny/2025 S 1284 Thathaiyangarpatty Primary Agricult

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