KULDIP SINGH,RANCHI vs. DCIT/ACIT, CIRCLE-1, RANCHI

ITA 180/RAN/2025Status: DisposedITAT Ranchi10 February 2026Bench: Shri Sonjoy Sarma (Judicial Member), Shri Ratnesh Nandan Sahay (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 issued beyond the four-year period stipulated in the first proviso to section 147, making it barred by limitation. The Tribunal also noted that the reassessment was based on the same material that was part of the original assessment, constituting a mere change of opinion, which is impermissible.

What were the facts?

The assessee, engaged in land and contract work, filed their income tax return for AY 2014-15. The original assessment under section 143(3) accepted the returned income. The Assessing Officer later issued a notice under section 148 for reassessment, alleging an escapement of income due to a discrepancy in land valuation.

What were the issues?

Whether the reopening of assessment under Section 147 was valid and not barred by limitation, considering the original assessment was completed under Section 143(3) and the notice was issued beyond four years without alleging failure to disclose material facts.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 56(2)(vii)(b)

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Income Tax Appellate Tribunal, BENCH-RANCHI

Before: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay

Per Sonjoy Sarma, Judicial Member:

This appeal filed by the assessee is directed against the order of the NFAC, Delhi (hereinafter referred to as “CIT(A)”) dated 06.03.2025 passed under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”).

2.

Brief facts of the case are that the assessee is engaged in the business of land and contract work. The assessee filed the return of income for the assessment year 2014–15 on 30.11.2014, declaring a total income of ₹40,80,800.

The order continues below.

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