HEMALATHA CHERVU,HYDERABAD vs. ITO, WARD - 15(1), HYDERABAD
What did the Tribunal hold?
The Tribunal held that the notice issued under Section 148 of the Act dated 06/04/2022 was barred by limitation as per the first proviso to Section 149(1) of the Act. Consequently, the assessment order passed by the AO was quashed.
What were the facts?
The assessee failed to file her income tax return for AY 2015-16. The assessment was reopened under Section 147, and a notice under Section 148 was issued on 06/04/2022. The Assessing Officer made additions under Section 69A for unexplained cash deposits and interest income.
What were the issues?
Whether the notice issued under Section 148 for reopening the assessment for AY 2015-16 was barred by limitation under the provisions of Section 149(1) of the Income Tax Act, 1961.
Which sections of the Income-tax Act were involved?
Section 147,Section 148,Section 144,Section 69A,Section 149(1)
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Cases cited in this judgment(1)Show listHide list
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- Raymond Woollen Mills Ltd. v. ITO862 citing236 ITR 34 · 1999 · SC
Income Tax Appellate Tribunal, Hyderabad ‘ B ‘ Bench, Hyderabad
Before: Shri Manjunatha G. & Shri Ravish Sood
Per MANJUNATHA, G. A.M. This appeal is filed by the assessee, feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 06/11/2025, for the A.Y 2015-16. 2. The brief facts of the case are that the assessee, an individual, not filed her return of income for the A.Y 2015-16. The ITA No 1966 of 2025 Hemalatha Chervu
assessment has been reopened under section 147 of the Income Tax Act, 1961, for the reasons recorded, as per
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