SUDARSANAM BHASKARAN,CHENNAI vs. ITO, NCW-10(3), CHENNAI

ITA 3657/CHNY/2025Status: DisposedITAT Chennai25 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 Act was invalid because it was issued beyond three years from the end of the relevant assessment year without obtaining approval from the Principal Chief Commissioner of Income Tax (PCCIT) as required by Section 151(ii). Consequently, the assessment order based on this invalid notice was quashed.

What were the facts?

The assessee did not file an income tax return. The Assessing Officer (AO) reopened the assessment based on information of property sale and assessed income. The CIT(A) upheld the addition, stating the assessee failed to provide evidence for acquisition/improvement costs.

What were the issues?

The primary issue was whether the notice for reassessment under Section 148 was validly issued, specifically concerning the required sanction from the appropriate authority under Section 151 when the notice was issued beyond three years from the end of the assessment year.

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

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

Hearing: 17.02.2026Pronounced: 25.02.2026

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 27.09.2025 for Assessment Year (AY) 2018-19. 2. The assessee is an individual and did not file the return of income. The Assessing Officer (AO) received information that the assessee has sold imm

The order continues below.

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