D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

ITA 1667/CHNY/2024Status: DisposedITAT Chennai21 January 2026AY 2014-1552 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that a reassessment notice under Section 148 cannot be issued when the assessment proceedings are still pending and the time for issuing a scrutiny assessment notice under Section 143(2) has not expired. This is because the original assessment is not yet terminated.

What were the facts?

The assessee trust filed a revised return of income. The Assessing Officer issued a notice for reassessment under Section 148 of the Income Tax Act while the time for issuing a notice for scrutiny assessment under Section 143(2) was still available.

What were the issues?

Whether a reassessment notice under Section 148 is valid when the time for issuing a scrutiny assessment notice under Section 143(2) is still available after filing a revised return.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(2),Section 139(5),Section 153

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Before: Shri S.S. Viswanethra Ravi & Shri Jagadish

For Appellant: Shri G. Baskar, Advocate &, Shri A. Satyaseelan, Advocate, Ms. Gouthami Manivasagam, JCIT

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

These four appeals filed by the assessee are directed against the orders all dated 05.04.2024 passed by the Id. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment years 2014-15, 2015-16, 2017-18 and 2018-19. 2. Since, the iss

The order continues below.

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