POWER SECURITY CORP. PVT. LTD.,CHENNAI vs. ITO, CORP. WARD-5(2), CHENNAI
What did the Tribunal hold?
The Tribunal held that the notice issued under Section 148 on 31.07.2022 was indeed barred by limitation as per Section 149, following the Supreme Court's decision in Rajeev Bansal. Consequently, all subsequent assessment proceedings were deemed invalid.
What were the facts?
The assessee's return for AY 2013-14 was reopened via a notice under Section 148 dated 31.07.2022, which was issued after the original notice under Section 148 (dated 30.06.2021) was deemed a notice under Section 148A. The assessee argued this notice was time-barred.
What were the issues?
Whether the notice issued under Section 148 was barred by limitation under Section 149, rendering the reassessment proceedings void ab initio. Whether the rejection of the rectification petition under Section 154 was justified.
Which sections of the Income-tax Act were involved?
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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.
- Union of India v. Rajeev Bansal713 citing167 Taxmann.com 70 · 2024 · SC · Read judgment
- ACIT v. Saurashtra Kutch Stock Exchange Ltd.470 citing305 ITR 227 · 2008 · SC · Read judgment
Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI
Before: SHRI ABY T. VARKEY & 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 01.10.2025 for Assessment Year (AY) 2013-14. The assessee raised the following ground of appeal:
“1. The order of the Ld. CIT(A) confirming the rejection of the rectifi
The order continues below.
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Similar judgments
Other orders that rely on the same authority or decide the same section.
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Also relies on Union of India v. Rajeev Bansal
The Tribunal noted that the Hon'ble Supreme Court, in the cases of Rajeev Bansal and Deepak Steel & Power Ltd., had held that notices issued for AY 2015-16 on or after 01.04.2021 are invalid and liable to be quashed as r...
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The Tribunal held that the notice issued under Section 148 on April 29, 2022, for AY 2015-16 was invalid and barred by limitation. The six-year limitation period under the old regime for AY 2015-16 expired on March 31, 2...
- Kantilal Ranchhodbhai Nakum, Jamnagar vs ITO Ward - 1(3), JamnagarRajkot13 Feb 2026Allowed
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The Tribunal held that the notice issued under Section 148A(d) was time-barred, as it was issued beyond the prescribed limitation period. Consequently, the reassessment order was quashed.
- Neeta Bhambhani, Bengaluru vs DCIT, (It), Circle-1(1), BengaluruBangalore12 Feb 2026Allowed
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More judgments on Section 148
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
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