SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

ITA 1223/HYD/2025Status: DisposedITAT Hyderabad25 February 2026AY 2017-1818 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessment order was barred by limitation as per Section 153(2) of the Income Tax Act, 1961, as it was passed beyond the prescribed time limit from the date of notice. The extended time limit under Section 153(4) was not applicable as there was no reference to the TPO.

What were the facts?

The assessee's case was selected for scrutiny under section 153C based on seized material from another company. The Assessing Officer (AO) made an addition of Rs. 4,26,80,000/- for unexplained investment in commercial property, alleging cash payment beyond banking channels.

What were the issues?

The primary issue was whether the assessment order passed under Section 153C r.w.s. 144C was barred by limitation. Another issue was the applicability of Section 69 to NRIs.

Which sections of the Income-tax Act were involved?

Section 153C,Section 144C,Section 153B,Section 69,Section 153(2),Section 153(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘B‘Bench, Hyderabad

Before: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Respondent: Shri P. Murali Mohan Rao, CA, Dr. Narendra Kumar Naik, CIT (DR)
Hearing: 22/01/2026

These four appeals filed by the assessee are directed against the separate assessment orders passed by the A. O under section 153C r.w.s. 144C(13) of the Income Tax Act, 1961, all dated 17/01/2025, for the Assessment. Years 2016-17 to 2019- 20 respectively. The assessee has raised similar grounds for all the four Assessment Years. Therefore, for the sake of convenience, these appeals were heard togeth

The order continues below.

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