STP ENTERPRISES,TIRUNELVELI vs. DCIT, CIRCLE-1,, TIRUNELVELI

ITA 3729/CHNY/2025Status: DisposedITAT Chennai27 February 2026AY 2018-19Bench: SHRI ABY T. VARKEY (Judicial Member), MS. PADMAVATHY.S (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 of the Income Tax Act was invalid because it was issued beyond three years from the end of the relevant assessment year without obtaining proper sanction from the Principal Chief Commissioner of Income Tax (PCCIT) as required by Section 151(ii). Consequently, the reassessment proceedings were vitiated.

What were the facts?

The assessee, a partnership firm engaged in fish export, did not file its income tax return. The Assessing Officer (AO) initiated reassessment proceedings, treating cash deposits and withdrawals as unexplained under Section 69A. The CIT(A) set aside the appeal to the AO for further examination.

What were the issues?

The primary issue was whether the reassessment proceedings were validly initiated, specifically concerning the adequacy of sanction obtained for issuing the notice under Section 148 beyond the prescribed time limit.

Which sections of the Income-tax Act were involved?

Section 69A,Section 148A,Section 148,Section 151,Section 147

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY.S

Hearing: 18.02.2026Pronounced: 27.02.2026

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 13.11.2025 for Assessment Year (AY) 2018-19. 2. The assessee is a partnership firm and engaged in the business of export of fish. The assessee did not file the return of income for the year under considerat

The order continues below.

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