GOVINDAN GNANAVEL,NAGAPATTINAM vs. ITO, WARD-1(1), TRICHY
What did the Tribunal hold?
The Tribunal held that the notice issued under Section 148 was invalid because it was issued beyond three years from the end of the relevant assessment year and lacked the mandatory approval from the Principal Chief Commissioner of Income Tax as required by Section 151(ii). Consequently, the reassessment proceedings were vitiated.
What were the facts?
The assessee did not file an income tax return, and the AO initiated reassessment proceedings due to high-value cash deposits. The AO issued a notice under Section 148 beyond the three-year period without obtaining the necessary approval from the Principal Chief Commissioner of Income Tax.
What were the issues?
Whether the reassessment proceedings initiated by issuing a notice under Section 148 beyond the prescribed time limit without obtaining the proper sanction from the competent authority as per Section 151(ii) are valid.
Which sections of the Income-tax Act were involved?
Section 147,Section 148,Section 148A,Section 151,Section 69A
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Cases cited in this judgment(2)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Core Logistic Company v. Assistant Commissioner of Income-tax26 citing175 Taxmann.com 453 · 2025 · HC
- Giriraj Commercial (P.) Ltd. v. Union of India12 citing169 Taxmann.com 168 · HC
Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI
Before: SHRI GEORGE GEORGE KAND MS. PADMAVATHY.S
PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order 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 12.09.2025 for Assessment Year (AY) 2018-19. 2. The assessee is an individual and did not file the return of income. The A.O noticed that the assessee has entered into high value transactions such as deposit of cash amounti
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- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
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