VIVEK RAMASWAMY PUTHUCODE,CHENNAI vs. ITO, INTERNATIONAL TAXATION WARD-2(1), CHENNAI

ITA 3731/CHNY/2025Status: DisposedITAT Chennai27 February 2026AY 2015-16Bench: SHRI ABY T. VARKEY (Judicial Member), MS. PADMAVATHY.S (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal admitted the assessee's additional ground that the notice under section 148 was barred by limitation, as it was a pure legal issue. Relying on Supreme Court judgments and concessions made by the Revenue, the Tribunal held that the notice issued for AY 2015-16 on 25.04.2022 under the new regime was beyond the permissible time limit.

What were the facts?

The assessee, an individual, did not file a return for AY 2015-16. The AO initiated reassessment proceedings by issuing notices under section 148A and 148 of the Income Tax Act, 1961. The assessee filed a return admitting income, but the AO made additions towards long-term capital gains. The CIT(A) provided partial relief, directing verification of an investment for deduction.

What were the issues?

Whether the notice issued under section 148 for AY 2015-16 dated 25.04.2022 is barred by limitation as per the provisions of section 149(1) of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 250,Section 148A,Section 148,Section 54,Section 149(1),Section 149(1)(b),Section 147,Section 153A,Section 153C,Section 132,Section 132A,Section 151

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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 15.10.2025 for Assessment Year (AY) 2015-16. 2. The assessee is an individual and did not file the return of income for AY 2015-16. T

The order continues below.

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