Union of India v. Rajeev Bansal

469 ITR 46Supreme Court of India2024#72 most cited

What is Union of India v. Rajeev Bansal authority for?

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

713

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2023 to 2026.

Also referred to as

Union of India v. Rajeev Bansal · Section 148 notice limitation · Ashish Agarwal legal fiction · TOLA applicability · reassessment jurisdiction · time-barred notice · order without jurisdiction · Section 149 · Section 148A

Also reported as

167 Taxmann.com 70301 Taxmann 238

Sections most often in play

Section 148Section 147Section 148ASection 151Section 149Section 144BSection 250Section 144
Read the full judgment

Issues it is cited on

section 149a(c)section 149a(d)section 149asection 151(i)section 149(1)(a)section 3(1)section 148a(a)section 148 noticesection 151(ii)section 149(1)section 149(1)(b)order under section 148a(d)

Judgments citing Union of India v. Rajeev Bansal

ACIT-5(2)(1), Mumbai vs. Nasher Miles Private Limited, Mumbai

In the result, both the appeal filed by the revenue department stands dismissed, whereas the Cos

ITA 5077/MUM/2025[2016-17]Status: DisposedITAT Mumbai31 Oct 2025AY 2016-17

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankarassessment Year: 2016-17 & Assessment Year: 2017-18 Acit, Circle-5(2)(1) Nasher Miles Private Room No. 571, Aaykar Bhavan, Limited Mk Road, Mumbai- 400020, Vs. 1601, Panchratna Building, Mumbai Opera House, Girgaon, Mumbai- 400004 Pan: Aabcs1385E (Appellant) (Respondent)

For Appellant: Ms. Sheetal JainFor Respondent: Shri Layaqat Ali Aafaqui, Ld. Sr. A.R
Section 147Section 148Section 151Section 250

…instant case admittedly the notice u/s 148 of the Act dated 30.07.2022 was issued after 3 years from the end of the A.Y. 2016-17 under new regime reassessment, in view of the judgment of Hon’ble Apex Court in the case of Union of India vs Rajeev Bansal (2024) 469 ITR 46 with the approval of PCIT-8, Mumbai but not of the Principle Chief Commissioner or Principle Director General or Chief Commissioner Or Co No. 254 & 255/M/2025 Nasher Mills Private Limited Director General as mandated u/s 151(ii) of the Act and therefore the ld. Commissioner by respectfully following the judgment of the Hon’ble Apex Court in the Ra…

R S Construction, Mumbai vs. Ward 41(3)(3), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4918/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-18

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 132Section 147Section 148Section 148ASection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) AND SMT. RENU JAUHRI (ACCOUNTANT MEMBER) I.T.A. No.4918/Mum/2025 Assessment Year: 2017-18 M/s R S Construction Vs. Income Tax Officer Room 16, A Basuwala Ward 41(3)(3), CHS Kokni Pada, Kurar Mumbai Village, Malad East, Income Tax Mumbai-400097 Department, National PAN:AATFR3944H Faceless Appeals Centre (NFAC), Delhi (Appellant) (Respondent) Appellant by Shri Fenil Bhat Respondent by Shri Umashankar Prasad, CIT D.R. Date of Hearing 15.10.2025 Date of Pronouncement 31.10.2025 ORDER Per: Smt. Beena Pillai, J.M.…

ACIT(It)-1(2)(1), Mumbai vs. Barclays Execution Services Limited, London

In the result, the appeal filed by the Revenue is dismissed and the cross-objection filed by the assessee is dismissed as infructuous

ITA 4253/MUM/2025[2017]Status: DisposedITAT Mumbai31 Oct 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 144CSection 147Section 148Section 148ASection 151

…vices Limited Principal Chief Commissioner was imperative. Admittedly, approval was obtained only from the CIT (IT-1), Mumbai. 10. The issue is no longer res integra in view of the law laid down by the Hon’ble Supreme Court in Union of India v. Rajeev Bansal (2024 SCC OnLine SC 2693), which has succinctly explained the scheme of Section 151 under the old and new regimes and the role of TOLA in extending time limits during the pandemic. The Apex Court emphasized that the specification of authority is inseparably linked to the elapsed time from the end of the assessment year, and that non-compliance goes to the roo…

ITO-15(3)(1), Mumbai vs. Sanjaykumar Shankarlal Export Private Limited, Navi Mumba

ITA 4157/MUM/2024[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 133ASection 147Section 148Section 148ASection 69C

…quential notices under section 148 of even date for both years. It was contended that in respect of A.Y. 2015–16, the notice is clearly barred by limitation under the new law as explained by the Hon’ble Supreme Court in Union of India v. Rajeev Bansal [(2024) 469 ITR 46 (SC)], since the six-year period under the old regime had already expired on 31 March 2022 and the new extended ten-year window could not be applied retrospectively. Learned counsel further submitted that Revenue itself had conceded before the Hon’ble Supreme Court that for A.Y. 2015–16, all notices issued on or after 1 by TOLA. He relied on a cat…

ACIT 27 1 Mumbai, Mumbai vs. Bhavesh Ranchhodas Madiyar, Mumbai

ITA 4028/MUM/2024[2014]Status: DisposedITAT Mumbai31 Oct 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 133ASection 147Section 148Section 148ASection 69C

…quential notices under section 148 of even date for both years. It was contended that in respect of A.Y. 2015–16, the notice is clearly barred by limitation under the new law as explained by the Hon’ble Supreme Court in Union of India v. Rajeev Bansal [(2024) 469 ITR 46 (SC)], since the six-year period under the old regime had already expired on 31 March 2022 and the new extended ten-year window could not be applied retrospectively. Learned counsel further submitted that Revenue itself had conceded before the Hon’ble Supreme Court that for A.Y. 2015–16, all notices issued on or after 1 by TOLA. He relied on a cat…

ACIT 27 1 Mumbai, Mumbai vs. Bhavesh Ranchhodas Madiyar, Mumbai

ITA 4026/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Oct 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 133ASection 147Section 148Section 148ASection 69C

…quential notices under section 148 of even date for both years. It was contended that in respect of A.Y. 2015–16, the notice is clearly barred by limitation under the new law as explained by the Hon’ble Supreme Court in Union of India v. Rajeev Bansal [(2024) 469 ITR 46 (SC)], since the six-year period under the old regime had already expired on 31 March 2022 and the new extended ten-year window could not be applied retrospectively. Learned counsel further submitted that Revenue itself had conceded before the Hon’ble Supreme Court that for A.Y. 2015–16, all notices issued on or after 1 by TOLA. He relied on a cat…

Sofia Twist and Text Pvt Ltd, Surat vs. DCIT Circle 2(1)(1), Surat

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

ITA 739/SRT/2025[2017-18]Status: DisposedITAT Surat30 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 Sofia Twist & Text Pvt Ltd, Dcit, Circle – 2(1)(1) 3003, Rathi Palace, Kamela Room No. 612, 6Th Floor, Darwaja, Ring Road, Vs. Aayakar Bhawan, Majurgate, Surat - 395002 Surat - 395002 Pan No. Aadcs4384F Appellant Respondent

For Appellant: Shri Ajay Uke, Sr. DRFor Respondent: Mr. Suresh K Kabra, CA
Section 148Section 151Section 68

…the Ld. Counsel for the assessee placed reli placed reliance upon the recent judgment of the ance upon the recent judgment of the Hon’ble Supreme Court Hon’ble Supreme Court in Union of India v. Rajeev Bansal & Union of India v. Rajeev Bansal & Others [(2024) 469 ITR 46 (SC)] [(2024) 469 ITR 46 (SC)] and submitted that the notice and submitted that the notice issued under Section 148 of the Act was manifestly beyond the issued under Section 148 of the Act was manifestly beyond the issued under Section 148 of the Act was manifestly beyond the limitation period as reckoned after limitation period as reckoned after…

Tirupati Shyam Enterprise, Surat vs. DCIT, Circle 1(1)(1), Surat

In the result, the appeal of the assessee is allowed

ITA 318/SRT/2025[2015-16]Status: DisposedITAT Surat30 Oct 2025AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-2016 Tirupati Shyam Enterprise Nfac, Delhi Current F.P. No. 139 Orleaans, Near Jurisdiction: Dy. Cit Circle- Sosyo Circle Udhna Magadalla Vs. 1(1)(1), Road, Surat-395007. Aayakar Bhavan, Near Majura Gate, Opp. New Civil Hospital, Surat-395001. Pan No. Aagft 3570 Q Appellant Respondent

For Appellant: Mr. J.K. Chandnani, Sr. DRFor Respondent: Mr. Rasesh Shah, CA
Section 147Section 148Section 5Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH “DB” SURAT BEFORE SHRI SANDEEP GOSAIN (JUDICIAL MEMBER) AND SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) Assessment Year: 2015-2016 Tirupati Shyam Enterprise NFAC, Delhi Current F.P. No. 139 Orleaans, Near Jurisdiction: Dy. CIT Circle- Sosyo Circle Udhna Magadalla Vs. 1(1)(1), Road, Surat-395007. Aayakar Bhavan, Near Majura Gate, Opp. New Civil Hospital, Surat-395001. PAN NO. AAGFT 3570 Q Appellant Respondent : Mr. Rasesh Shah, CA Assessee by : Mr. J.K. Chandnani, Sr. DR Revenue by : 09/10/2025 Date of Hearing Date of pronouncement : 30/10/2025 ORDER PER OM PRAKASH…

Jigneshbhai Arvindbhai Patel, Surat vs. ITO, Ward 2(3)(2), Surat

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

ITA 272/SRT/2025[2013-14]Status: DisposedITAT Surat30 Oct 2025AY 2013-14

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2013-2014 Jigneshbhai Arvindbhai Patel, Ito Ward-2(3)(2), 84, Angreji Faliyu, Opp. Post Income Tax Office, Majura Gate, Office, Amroli, Surat-394107. Vs. Surat-395001. Pan No. Bczpp 8713 R Appellant Respondent

For Respondent: Mr. Sapnesh Sheth, Advocate
Section 148Section 50C

…ndered by the Hon’ble Supreme Court in the case of Union Union of India and others Vs Ashish of India and others Vs Ashish Agarwal (2022) 444 ITR 1 (SC) (2022) 444 ITR 1 (SC) and Union of India v. Rajiv Bansal & Union of India v. Rajiv Bansal & Others, (2024) 469 ITR 46(SC) (2024) 469 ITR 46(SC) the impugned notice issued under the impugned notice issued under Section 148 of the Income Section 148 of the Income-tax Act, 1961 (“the Act”) stands vitiated tax Act, 1961 (“the Act”) stands vitiated being issued beyond the period of limitation permissible under law. being issued beyond the period of limitation permissi…

DCIT, Circle 4(2), New Delhi vs. Sh. Vikram Bakshi, New Delhi

ITA 453/DEL/2025[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandradcit, Circle 4(2) Vs. Sh. Vikram Bakshi Room No. 384, 157, Golf Links 157 Golf C. R. Building Links, Lodi Road, H.O. Delhi – 110002 Kasturba Nagar South East Delhi 110003, Delhi "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aenpb4926R Appellant .. Respondent

For Appellant: Sh. C.S. Anand, Adv, &For Respondent: Sh. Rajesh Kumar Dhanesta
Section 147Section 148Section 148A

…was furnished by the assessee. On 25.07.2022 the order under Section 148A(d) was passed and notice under Section 148 of the Act was issued as per the order passed by the Hon’ble Supreme Court in the case of Union of India & Ors. Vs. Rajiv Bansal, reported in 469 ITR 46 whereas in paragraph 112, the specific guideline has been framed that the time limit for issuance of notice under Section 148 of the Act under the new regime ended on 01.07.2022 i.e. 7 days after 24.06.2022 the date when the reply to the notice under Section 148A(b) was furnished by the assessee. In that view of the matter, the notice under Sectio…

Artline Finance Pvt Ltd, Delhi vs. DCIT, Central Circle-8, Delhi

In the result, Appeal of the Assessee is allowed

ITA 3705/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandraartline Finance Pvt. Ltd. Vs Dcit (Earlier Known As Central Circle-8 Artlinevinimay Pvt. Ltd.) No. Delhi 8 Ground Floor, Todal Mal Lane, Bengali Market, Delhi Pan: Aacca5237E Appellant Respondent Assessee By Sh. Amit Goel, Adv, Shri Pranav Yadav, Adv Revenue By Ms.Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16/10/2025 Date Of Pronouncement 29/10/2025 Order Per Yogesh Kumar, U.S. Jm:

Section 148Section 148ASection 149Section 149(1)

…upreme Court in Union of India &Ors. v. Ashish Agarwal (supra). The Supreme Court also granted further time to provide the material, which was required to accompany such notice. As explained by the Supreme Court in the case of Union of India v. Rajeev Bansal: 2024 SCC OnLine SC 2693, the period from the date of the issuance of the notice till 04.05.2022, the date on which the Supreme Court had rendered the decision in Union of India &Ors. v. Ashish Agarwal (supra), is required to be excluded. Additionally, the time provided till the date of providing the material, which should have accompanied a notice under Sect…

Sangeeta Khandelwal, New Delhi vs. DCIT, Circle 28 (1), Delhi, New Delhi

In the result, Appeals of the Assessee are allowed

ITA 2495/DEL/2025[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

Section 148Section 148ASection 149Section 149(1)

…upreme Court in Union of India &Ors. v. Ashish Agarwal (supra). The Supreme Court also granted further time to provide the material, which was required to accompany such notice. As explained by the Supreme Court in the case of Union of India v. Rajeev Bansal: 2024 SCC OnLine SC 2693, the period from the date of the issuance of the notice till 04.05.2022, the date on which the Supreme Court had rendered the decision in Union of India &Ors. v. Ashish Agarwal (supra), is required to be excluded. Additionally, the time provided till the date of providing the material, which should have accompanied a notice under Sect…

Sangeeta Khandelwal, New Delhi vs. DCIT, Circle 28 (1), Delhi, New Delhi

In the result, Appeals of the Assessee are allowed

ITA 2494/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

Section 148Section 148ASection 149Section 149(1)

…upreme Court in Union of India &Ors. v. Ashish Agarwal (supra). The Supreme Court also granted further time to provide the material, which was required to accompany such notice. As explained by the Supreme Court in the case of Union of India v. Rajeev Bansal: 2024 SCC OnLine SC 2693, the period from the date of the issuance of the notice till 04.05.2022, the date on which the Supreme Court had rendered the decision in Union of India &Ors. v. Ashish Agarwal (supra), is required to be excluded. Additionally, the time provided till the date of providing the material, which should have accompanied a notice under Sect…

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4671/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

…for AY 2016-17 CO Nos.126, 104 & 105/Del/2025 as the same is issued without prior approval of the specified authority under the new regime in view of the judgement rendered by Hon’ble Supreme Court in the case of ‘Union of India and Others vs. Rajeev Bansal [2024 SCC OnLine SC 2693]’. 21. In this regard, we observe that the notice dated 30.06.2021 by the AO under section 148 of the Act is illegal, bad in law, and without jurisdiction as the same has been issued without taking the valid approval/satisfaction from the prescribed authority mentioned under Section 151 of the Act. Further, we observe that under Secti…

DCIT, Circle - 10(1), New Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4670/DEL/2024[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

…for AY 2016-17 CO Nos.126, 104 & 105/Del/2025 as the same is issued without prior approval of the specified authority under the new regime in view of the judgement rendered by Hon’ble Supreme Court in the case of ‘Union of India and Others vs. Rajeev Bansal [2024 SCC OnLine SC 2693]’. 21. In this regard, we observe that the notice dated 30.06.2021 by the AO under section 148 of the Act is illegal, bad in law, and without jurisdiction as the same has been issued without taking the valid approval/satisfaction from the prescribed authority mentioned under Section 151 of the Act. Further, we observe that under Secti…

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4669/DEL/2024[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

…for AY 2016-17 CO Nos.126, 104 & 105/Del/2025 as the same is issued without prior approval of the specified authority under the new regime in view of the judgement rendered by Hon’ble Supreme Court in the case of ‘Union of India and Others vs. Rajeev Bansal [2024 SCC OnLine SC 2693]’. 21. In this regard, we observe that the notice dated 30.06.2021 by the AO under section 148 of the Act is illegal, bad in law, and without jurisdiction as the same has been issued without taking the valid approval/satisfaction from the prescribed authority mentioned under Section 151 of the Act. Further, we observe that under Secti…

Bangamata Tie-Up Private Limited, Kolkata vs. ITO 13(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1332/KOL/2025[2015-16]Status: DisposedITAT Kolkata28 Oct 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Bangamata Tie-Up Private Ito 13(1) Limited Aaykar Bhawan, 41, Central Plaza, Bb Ganguly Kolkata-700069, West Bengal Vs. Street Bowbazar, Kolkata-700012, West Bengal (Appellant) (Respondent) Pan No. Aaecb9495M Assessee By : Shri Akshay Ringasia, Ar Revenue By : Shri Soumitra Ghosh, Dr Date Of Hearing: 21.08.2025 Date Of Pronouncement: 28.10.2025

For Appellant: Shri Akshay Ringasia, ARFor Respondent: Shri Soumitra Ghosh, DR
Section 147Section 148Section 148ASection 149

…Hon'ble Supreme Court in the case of NTPC 229 ITR 383. That the Ld. AO erred in issuing notice under section 148 beyond the time limit prescribed under section 149 and settled in case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) That since the above ground goes to the root of the matter and permeates from facts already on record before the lower authorities and this Hon'ble Tribunal, your assessee prays for the admission of the same in the interest of justice.” 02. The only issue raised by the Counsel of the assessee is in respect of A.Y. 2015-16, being time barred b…

Sivadurgavara Prasad Chennupati, Vijayawada vs. Assistant CIT, Circle 2(1), Vijayawada

In the result, the appeal by the assessee is allowed

ITA 368/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Oct 2025AY 2016-17

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailita No.368/Viz/2025 (Assessment Year 2016-17) (Assessment Year 2016-17) Sivadurgavara Prasad Chennupati, H. No. 27-32-27, Raghu Paints, Mudda Subbaiah Street, Governorpet, Vijayawada ............... Appellant Pan: Aeepc5404L V/S Assistant Commissioner Of Income Tax, Circle – 2(1), ……………… Respondent C R Building, 1St Floor Annex, M.G. Road, Vijayawada Assessee By : Shri C.R. Hemanth Kumar, Ca Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Shri C.R. Hemanth Kumar, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 149(1)Section 250Section 28

…31/03/2021, and even if the extension granted by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (“the TOLA”), in light of the decision of the Hon’ble Supreme Court in Union of India v/s Rajeev Bansal, reported in (2024) 469 ITR 46 (SC), is considered, the AO had time only till ITAs No.367 & 368/Viz/2025 (A.Ys. 2016-17) 5 15/06/2022 to issue notice under section 148 of the Act. Therefore, the learned AR submitted that the notice issued under section 148 of the Act on 27/07/2022 for the assessment year 2016-17 is barred by limitation. Hence, it was submitted that the entire…

Siva Durga Vara Prasad Chennupati, Vijayawada vs. Assistant Commissioner of Income Tax, Circle 2(1), Vijayawada

In the result, the appeal by the assessee is allowed

ITA 367/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Oct 2025AY 2016-17

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailita No.368/Viz/2025 (Assessment Year 2016-17) (Assessment Year 2016-17) Sivadurgavara Prasad Chennupati, H. No. 27-32-27, Raghu Paints, Mudda Subbaiah Street, Governorpet, Vijayawada ............... Appellant Pan: Aeepc5404L V/S Assistant Commissioner Of Income Tax, Circle – 2(1), ……………… Respondent C R Building, 1St Floor Annex, M.G. Road, Vijayawada Assessee By : Shri C.R. Hemanth Kumar, Ca Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Shri C.R. Hemanth Kumar, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 149(1)Section 250Section 28

…31/03/2021, and even if the extension granted by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (“the TOLA”), in light of the decision of the Hon’ble Supreme Court in Union of India v/s Rajeev Bansal, reported in (2024) 469 ITR 46 (SC), is considered, the AO had time only till ITAs No.367 & 368/Viz/2025 (A.Ys. 2016-17) 5 15/06/2022 to issue notice under section 148 of the Act. Therefore, the learned AR submitted that the notice issued under section 148 of the Act on 27/07/2022 for the assessment year 2016-17 is barred by limitation. Hence, it was submitted that the entire…

Anupama Vintrade Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1313/KOL/2025[2015-16]Status: DisposedITAT Kolkata27 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Anupama Vintrade Pvt. Ltd..….……………………….……….……….……Appellant 77, 4Th Floor, Room 422, Elliot Road, Kol-700016.. [Pan: Aahca5675R] Vs. Ito, Ward-10(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Somnath Ghosh, Advocate, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.03.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Appeal Has Been Filed By The Assessee With A Delay Of 14 Days. 2. The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Considering The Reasons Cited In The Affidavit For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 133(6)Section 143(1)Section 147Section 148Section 148ASection 149(1)(b)Section 250

…आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA Before Shri Rajesh Kumar, Accountant Member and Shri Pradip Kumar Choubey, Judicial Member Assessment Year: 2015-16 Anupama Vintrade Pvt. Ltd..….……………………….……….……….……Appellant 77, 4th Floor, Room 422, Elliot Road, Kol-700016.. [PAN: AAHCA5675R] vs. ITO, Ward-10(2), Kolkata….……………………………….....……...…..…..Respondent Appearances by: Shri Somnath Ghosh, Advocate, appeared on behalf of the appellant. Shri Manas Mondal, Addl. CIT-Sr. DR, appeared on behalf of the Respondent. Date of concluding the hearing : October 16, 2025 Da…