SHRI RADHA KRISHNA ISPAT PRIVATE LIMITED,KALUNGA vs. ASSISTANT COMMISSIONER OF INCOME TAX, ACIT CIRCLE ROURKELA, ROURKELA

ITA 19/CTK/2026Status: DisposedITAT Cuttack27 February 2026AY 2015-16Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal noted that the Hon'ble Supreme Court, in the cases of Rajeev Bansal and Deepak Steel & Power Ltd., had held that notices issued for AY 2015-16 on or after 01.04.2021 are invalid and liable to be quashed as reassessment proceedings could not be completed within the statutory time prescribed under TOLA.

What were the facts?

The assessee filed an appeal against the order of the CIT(A) for AY 2015-16. The assessee raised an additional ground challenging the validity of the notice issued under Section 148 of the Income Tax Act, 1961, dated 30.06.2021, stating it is barred by limitation.

What were the issues?

Whether the notice issued under Section 148 of the Income Tax Act, 1961, for AY 2015-16, dated 30.06.2021, is barred by limitation and invalid in law.

Which sections of the Income-tax Act were involved?

Section 254(1),Section 148,Section 147

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, CUTTACK BENCH CUTTACK

Before: SHRI GEORGE MATHAN & SHRI MADHUSUDAN SAWDIAShri Radha Krishna Ispat Private

For Appellant: Shri Saswat Kumar Acharya &, Shri Abhijit Agarwal, A.Rs
For Respondent: Shri Ashim Kumar Charkaborty, CIT-DR
Hearing: 27/02/2026Pronounced: 27/02/2026

PER: BENCH

1.

This is an appeal filed by the assessee against the order of the ld. CIT(A), NFAC, Delhi in Appeal No. NFAC/2014-15/10282014 dated 28/11/2025 for the A.Y. 2015-16. 2. The assessee has raised additional ground of appeal, which reads as follows:

“1. As per Section 254(1) of Income Tax Act, 1961 r/w. Rule 11 of the ITAT Rules, 1963, the following additional grounds which could not be taken specifically and separately and which do not involve investigation into fresh facts but go the very root of the assessment, may kindly be admitted in the interests of justice as the same challenges the 'legality’ of

The order continues below.

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