D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

ITA 1670/CHNY/2024Status: DisposedITAT Chennai21 January 2026AY 2018-19Bench: Shri S.S. Viswanethra Ravi (Judicial Member), Shri Jagadish (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the notice for reassessment under section 148 was not maintainable because a revised return was pending and the notice was issued beyond the permissible time limit for issuing a notice under section 143(2). Consequently, the reassessment order was quashed.

What were the facts?

The assessee trust's reassessment proceedings were challenged on grounds of limitation, failure to provide actual reasons for reopening, and change of opinion. The Tribunal noted that a revised return was filed, and the notice for reassessment was issued after the limitation period for issuing a notice under section 143(2) had expired.

What were the issues?

Whether the reassessment proceedings were validly initiated considering the pendency of a revised return and the limitation period for issuing a notice under section 143(2).

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(2),Section 139(5),Section 11

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

Hearing: 28.10.2025Pronounced: 21.01.2026

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 ld. 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 issues raised in these appeals are simi

The order continues below.

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