“Section 149(1)(a)”

Section References (mined)Section 149Section 149(1)(a)180 judgments

SHAILESH KUMAR,NEW DELHI vs. CENTRAL CIRCLE- 27, NEW DELHI

In the result, Appeal of the Assessee is allowed

ITA 3641/DEL/2025[2015-16]Status: DisposedITAT Delhi18 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Amitabh Shuklashailesh Kumar Vs Acit W-82/1, Eastern Avenue, Sainik Central Circle-27 Farms, New Delhi Jhandewalan, New Delhi Pan: Afppk1645B (Applicant) (Respondent) Appellant By Sh. R. P. Mall, Adv Respondent By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 26.02.2026 Date Of Pronouncement 18.03.2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-29, (‘Ld. Cit (A)’ For Short), New Delhi Dated 28/03/2025 For The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That, Assessee Filed Its Return Of Income For The Year Under Consideration Declaring Income Of Rs. 18,18,380/-. An Assessment Order Came To Be Passed U/S 147 Of The Act On 30/05/2023 By Computing The Income Of The Assessee At Rs. 72,84,905/- As Against The Returned Income Of Rs. 18,18,380/-. Aggrieved By The Assessment Order Dated 30/05/2023, Assessee Preferred Appeal Before The Ld. Cit(A). The Ld. Cit(A) Vide Order Dated 28/03/2025, Dismissed The Appeal Of The Assessee.

Section 147Section 148Section 148ASection 149Section 149(1)Section 149(1)(b)Section 3(1)

notices issued under the old regime for Assessment Year 2015-16, since the limitation period of three or six years, as prescribed under section 149(1) of the Act, did not fall within the period from 20.03.2020 to 31.03.2021, to which TOLA applies. 9. Further in the judgment ... where the Court held that section 3(1) of TOLA cannot operate to extend the limitation period beyond what is prescribed under section 149(1)(b) of the un-amended Act, as it only applies where the original limitation expired between 20.03.2020 and 31.03.2021. For Assessment Year

BMR OVERSEAS LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(2), C.R. BUILDING DELHI 110002, DELHI

In the result the appeal of the assessee is allowed

ITA 6646/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Bmr Overseas Limited, Vs. Dcit, Circle 4(2), Zb-33/487, Plot No. 4 & 5, C.R. Building, Dilshad Garde New Delhi Industrial Area, Shahdara, Delhi – 110 095 [Pan No. Aafcb8509D) (Appellant) (Respondent)

Section 115BSection 143Section 147Section 148Section 151Section 156Section 157ASection 68

u/s.151 of the new regime for the notices issued in terms of Ashish Agrawal (supra) after 01.04.2021. Reference by ld. Sr. DR to Section 149(1)(a) deals with time limit for issuing notice u/s.148. Contention of the ld. Sr. DR that there is no hierarchical escalation for obtaining prior

SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

In the result, the appeal of the assessee is allowed

ITA 646/RJT/2025[2016-17]Status: DisposedITAT Rajkot12 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 646/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Shiv Extrusion Vs. Income Tax Officer Plot No.3978 Phase Iiiroad Income Tax Office, Ito Ward No.-R Dared, Jamnagar 2(10), Jamnagar, Income 361004, Gujarat, India, Jamnagar Tax Office, Shiv Smruti, Jamnagar, Jamnagar, Gujarat, 361008, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abkfs7199F (Appellant) (Respondent) Appellant By : Shri Ramesh M. Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23/12/2025 Date Of Pronouncement : 12/03/2026

For Appellant: Shri Ramesh M. Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR

Section 144BSection 147Section 148Section 149Section 149(1)(b)Section 151Section 151(1)Section 151ASection 250

follows: - 1. 1. Jurisdictional Defects (Limitation and Threshold Failure) 1. Invalid Assumption of Jurisdiction due to Retrospective Failure of Monetary Tinreshold (Section 149(1)(b)): The NFAC erred in sustaining the reassessment initiated under the extended period of limitation prescribed by Section 149(1)(b) despite the final assessed income ... threshold of Rupees fifty lakhs or more. -The AD relied on the entire alleged turnover of Rs. 1,17,14,220/- to invoke Section 149(1)(b). The NFAC itself conceded the settled legal position that only the profit embedded in such sales is taxable, not the entire turnover. Since

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

In the result, appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 459/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam04 Mar 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 44ASection 69A

dated 03.04.2022 on the ground that the same was barred by limitation by virtue of the “first proviso” to section 149(1) of the Act, which is purely a legal issue and would not require looking any further beyond the facts borne on record, therefore, we have no hesitation ... contention, the Ld. AR submitted that as the AO as per the “first proviso” to Page. No 7 I.T.A.No.459/VIZ/2025 Srinivasa Rao Sirivuri section 149(1) of the Act as was applicable at the time of issuing the notice under section 148 of the Act, dated 03.04.2022, was divested

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

In the result, appeal filed by the assessee is partly allowed

ITA 3294/CHNY/2025[2015-16]Status: DisposedITAT Chennai04 Mar 2026AY 2015-16

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

notice u/s 148 of the Act issued on\n07.04.2022 was beyond the period of limitation as prescribed in the\nproviso to Section 149(1) of the Act read with the provision that existed\n01.04.2021 as referred to in the newly amended first proviso referred to\nabove.\nThe admitted facts ... assessment passed in\nconsequence to issuance of notice under Section 148 of the Act is\nsubjected to the conditions prescribed under Section 149(1)(a) of the Act.\nThe term “Income assessable to tax” was interpreted by the Karnataka\nHigh Court in the case reported in 455 ITR 370, wherein

JUEE SUDHIR GORE,MUMBAI vs. ITO WARD-42(2)(3) , MUMBAI

The appeal is allowed

ITA 5868/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Mar 2026AY 2017-18

Bench: Justice (Retd.) C.V. Bhadang & Shri Vikram Singh Yadav: A.Y. : 2017-18

For Appellant: Shri Kumar KaleFor Respondent: Ms. Nidhi Agarwal, Sr. DR

Section 144BSection 147Section 148Section 148ASection 149(1)(a)Section 149(1)(b)Section 151Section 56(2)(x)

Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (‘TOLA’ for short) expired on 02.07.2022. It was also contended that the mandate of Section 149(1)(b) of the Act is violated. 4. The learned CIT(A) has refused to accept the challenge and dismissed the appeal by the impugned ... particularly when the possession was also obtained in 2008 and the Occupation Certificate was issued on 16.02.2000. It is next contended that under Section 149(1)(a) of the Act, the notice under Section 148 of the Act could not have been issued more than three years from

NISTALA SUDHA,KEONJHAR vs. ITO., WARD-9(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

ITA 605/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad26 Feb 2026AY 2016-2017

Bench: Shri Manjunatha, G.A N D Shri Ravish Soodआ.अपी.सं /Ita No./605/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Nistala Sudha Vs. Ito Keonjhar, Odhisha Ward 9(1) Pan:Emcps9399C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri D. Parida, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 25/02/2026 घोषणा की तारीख/Pronouncement: 26/02/2026 आदेश/Order Per Manjunatha, G. A.M.

For Appellant: Shri D. Parida, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 147Section 148Section 148ASection 69A

assessment beyond 3 years from the end of the relevant A.Y, even though escaped income does not exceed Rs.50 lakhs in terms of section 149(1)(b) of the Act. Therefore, he submitted that the reopening of the assessment is bad in law and liable to be quashed ... through the orders of the Page 6 of 10 ITA No 605 of 2025 Nistala Sudha authorities below. As per the provisions of section 149(1)(a) of the Act, no notice u/s 148 shall be issued for the relevant A.Y, if 3 years have elapsed from

ITO 13(2)(1), MUMBAI vs. SKA SALES PRIVATE LIMITED, MUMBAI

ITA 5967/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Prakash Jhunjhunwala &For Respondent: Shri Nakul Agrawal

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

were amended vide the Finance Act of 2021, with effect from 1st April, 2021. Assessment Year 2017-2018 1.2 As per the unamended section 149(1)(a) of the Act of 1961, the reassessment proceedings could be initiated within 4 years from the end of the relevant Assessment Years ... unamended section 149(1)(b) of the Act of 1961, the reassessment proceedings could be initiated within 6 years from the end of the relevant AY if the income chargeable to tax that has escaped assessment amounts to one lakh rupees or more for that year

SKA SALES PVT LTD,MUMBAI vs. INCOME TAX OFFICSR, WARD 13(2)(1), MUMBAI

ITA 5527/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

were\namended vide the Finance Act of 2021, with effect from 1st April,\n2021.\n1.2 As per the unamended section 149(1)(a) of the Act of 1961,\nthe reassessment proceedings could be initiated within 4 years\nfrom the end of the relevant Assessment Years ('AYs').\n1.3 ... unamended section 149(1)(b) of the Act of 1961,\nthe reassessment proceedings could be initiated within 6 years\nfrom the end of the relevant AY if the income chargeable to tax\nthat has escaped assessment amounts to one lakh rupees or more\nfor that year.\n1.4

SUDHA DOSHI,HYDERABAD vs. ITO - WARD 5(1), HYDERABAD

ITA 1775/HYD/2025[2015-16]Status: DisposedITAT Hyderabad25 Feb 2026AY 2015-16

For Appellant: Shri S. VenkateshwarluFor Respondent: Shri K. Vamsi Krishna

Section 143(3)Section 147Section 148Section 148ASection 151ASection 250(6)

144B of the\nAct, dated 24/05/2023. Elaborating on his contention, the Ld. AR\nsubmitted that as the AO as per “first proviso” to section 149(1) of the\nAct (post amended) as was applicable at the time of issuing the notice\nunder section 148 of the Act, dated 30/07/2022 ... relate to the\nun-amended section 149 of the Act, which in turn is taken care of\nexclusively by the \"first proviso” to section 149(1) of the Act. Accordingly,\nthe Ld. AR based on his aforesaid contentions submitted that the time\nspent from the issuance of notice under section

HOTEL SELECTION GRAND,TADEPALLIGUDEM vs. INCOME TAX OFFICER, WARD-1, TADEPALLIGUDEM

ITA 741/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2016-17

Section 115BSection 142ASection 147Section 148Section 148ASection 149(1)(b)Section 151ASection 234ASection 69A

inserted by the Finance Act, 2021, w.e.f\n01.04.2021} being beyond six years from the end of the assessment year as\nper the provisions section 149(1)(b) existing upto 31.03.2021.\n2.\nThe notice issued under section 148 dated 18.04.2023 is invalid as\nit has given only 30 days-time from ... ninformation in the possession of the Assessing Officer which reveal\nthat income chargeable to tax has escaped assessment as mandated\nby section 149(1)(b).\nii) The Notice U/s 148 is based on D.V.O. report which is on a\ninvalid reference made by the Assessing Officer having not been\nmade

ANDHRA PRADESH HOUSING BOARD,VIJAYAWADA vs. ACIT/DCIT, CIRCLE-1(1), VIJAYAWADA

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 732/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 143(2)Section 147Section 148Section 148ASection 250

Housing Board Act, dated 19.03.2024. Elaborating on his contention, the Ld. AR submitted that as the AO as per the “first proviso” to section 149(1) of the Act (post-amended) as was applicable at the time of issuing the notice under section 148 of the Act, dated ... struck down on account of invalid assumption of jurisdiction. The Ld. AR to buttress his contention had drawn our attention to section 149(1) of the Act - “first proviso” (as was made available on the statute by the Finance Act, 2021, w.e.f. 01/04/2021). 8. Carrying his contention further

EXEL RUBBER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next ... finding at the time of granting the sanction as to why the reopening beyond 3 years is in accordance with the provisions of section 149(1)(b) of the Act. The alleged material which is the basis of reopening of the assessment does not reveal the fact that the income

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD, HYDERABAD

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

CHODAY JANAKI RAMAYYA CHOWDARY,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1, KAKINADA

In the result, the appeal filed by the assessee is allowed in terms of my aforesaid observations

ITA 623/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam16 Feb 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble

Section 147Section 148Section 148ASection 69A

144B of the Act, dated 19.02.2024. Elaborating on his contention, the Ld. AR submitted that as the AO as per “first proviso” to section 149(1) of the Act (post amended) as was applicable at the time of issuing the notice under section 148 of the Act, dated ... struck down on account of invalid assumption of jurisdiction. The Ld. AR to buttress his contention had drawn my attention to section 149(1) of the Act - “first proviso” (as was made available on the statute by the Finance Act, 2021, w.e.f. 01/04/2021). 9. Carrying his contention further

KANTILAL RANCHHODBHAI NAKUM,JAMNAGAR vs. ITO WARD - 1(3), JAMNAGAR

In the result, appeal filed by the assessee is allowed

ITA 551/RJT/2025[2015-16]Status: DisposedITAT Rajkot13 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.551/Rjt/2025 Assessment Year: 2015-16 Kantilal Ranchhodbhai Nakum Income Tax Officer, Ward-1(3), Plot No.762, Gidc, Phase-2, बनाम/ Jamnagar, Aaykar Bhawan, Nr. Dared, Jamnagar-361 004 Vs. Chamber Of Commerce Hall, Jamnagar- Rajkot Highway, Jamnagar-361 001 "ायीलेखासं/.जीआइआरसं./ Pan/Gir No.: Aflpn 8072 P (अपीलाथ"/Appellant) (""थ"/Respondent) : िनधा"रती की ओर से/Assessee By : Shri Ravindra Manek, Ar राज" की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख/Date Of Pronouncement : 13/02/2026 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2015-16, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals) [In Short, “Cit(A)”] Dated 29.07.2025, Which In Turn Arises Out Of An Assessment Order Passed By Assessing Officer U/S 147 R.W.S. 144B Of The Act, On 12.05.2023. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1.The Hon’Ble Cit(A) Erred In Law & On Facts In Confirming Reopening Of Assessment U/S 148 Of The Act.

For Appellant: Shri Ravindra Manek, ARFor Respondent: Shri Sanjay Punglia, CIT-DR

Section 144BSection 147Section 148Section 148ASection 234ASection 250Section 271(1)(c)

after 01.04.2021 would be time barred, as three years from assessment year (AY) 2015-16, got expired on 31.03.2019, as per amended section 149(1)(a) of the Act, as applicable from 01.04.2021. Therefore, we find that notice u/s 148 of the Act was beyond time allowed as held ... time barred. That is, the time limit of 6 years from the end of assessment year 2015-16, bearing in mind Section 149(1)(b) of the Act, as it existed prior to 4 Kantilal R Nakum 01.04.2021, then notice u/s 148A(b) would be time barred

NILESHKUMAR M BHALODI,RAJKOT vs. THE INCOME TAX OFFICER, WARD - 2(1)(1), RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

ITA 7/RJT/2026[2015-16]Status: DisposedITAT Rajkot10 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Ms Devina Patel, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 250

after 01.04.2021 would be time barred, as three years from assessment year (AY) 2015-16, got expired on 31.03.2019, as per amended section 149(1)(a) of the Act, as applicable from 01.04.2021. Therefore, we find that notice u/s 148 of the Act was beyond time allowed as held ... time barred. That is, the time limit of 6 years from the end of assessment year 2015-16, bearing in mind Section 149(1)(b) of the Act, as it existed prior to 01.04.2021, then notice u/s 148A(b) would be time barred by 31.03.2022. The Page

SANJAYKUMAR HARIBHAI PARSANA,RAJKOT vs. DCIT/ACIT CIR 1(1), RKT, RAJKOT

In the result, appeal filed by the assessee is allowed

ITA 596/RJT/2025[2015-16]Status: DisposedITAT Rajkot10 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Rajendra Singhal, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR

Section 147Section 148Section 148ASection 149(1)(a)Section 250Section 69

after 01.04.2021 would be time barred, as three years from assessment year (AY) 2015-16, got expired on 31.03.2019, as per amended section 149(1)(a) of the Act, as applicable from 01.04.2021. Therefore, we find that notice u/s 148 of the Act was beyond time allowed as held ... time barred. That is, the time limit of 6 years from the end of assessment year 2015-16, bearing in mind Section 149(1)(b) of the Act, as it existed prior to 01.04.2021, then notice u/s 148A(b) would be time barred by 31.03.2022. The decision

Showing 1–20 of 180 · Page 1 of 9

...