SRINIVASA RAO SIRIVURI PROPRIETOR,VIZIANAGARAM vs. INCOME TAX OFFICER, VIZIANAGARAM

ITA 459/VIZ/2025Status: DisposedITAT Visakhapatnam04 March 2026AY 2015-16Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI OMKARESHWAR CHIDARA, HON’BLE ACCOUNTANT MEMBER आयकर अपीलसं./I.T.A.No.459/VIZ/2025 (निर्धारण वर्ा/ Assessment Year:2015-16) Srinivasa Rao Sirivuri 9-1-85, Hukumpeta Kotta Road Near Silver Company Vizianagaram – 535002 Andhra Pradesh [PAN: FPSPS5851B] Vs. Income Tax Officer Income Tax Office Koppugurana Building Siddhartha Nagar Vizianagaram – 535002 Andhra Pradesh करदाता का प्रतततितित्व/ Assessee Represented by : Shri G.V.N. Hari, Advocate रा23 pages
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What did the Tribunal hold?

The Tribunal held that the notice issued by the AO under section 148 was barred by limitation as per the first proviso to section 149 of the Act. Consequently, the assessment order passed by the AO was quashed for want of valid assumption of jurisdiction.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under section 147 for AY 2015-16 based on information about substantial cash deposits in the assessee's bank account. The assessee failed to file a return or comply with notices, leading the AO to make an addition of Rs. 89,57,554/- under section 69A as unexplained cash. The CIT(A) upheld this addition.

What were the issues?

The primary issue was whether the notice issued under section 148 was within the prescribed period of limitation, considering the amendments brought by the Finance Act, 2021.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 69A,Section 115BBE,Section 148,Section 142(1),Section 133(6),Section 148A,Section 149

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Income Tax Appellate Tribunal, VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM

Before: SHRI RAVISH SOOD, HON’BLE & SHRI OMKARESHWAR CHIDARA, HON’BLE

For Appellant: Shri G.V.N. Hari, Advocate
Pronounced: 04.03.2026

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (for short “CIT(A)”), dated 20.12.2024, which in turn arises from the order

I.T.A.No.45

The order continues below.

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